is it a requirement to have a CRA policy
Posted By: RR Jen
Re: CRA policy - 02/14/17 07:52 PM
There isn't any language in the regulation indicating a policy requirement that I'm aware of, but with the other various requirements I wouldn't want to operate without one.
Posted By: Mel in WA
Re: CRA policy - 03/14/19 04:44 PM
My bank has a CRA policy. Does it need to be approved by the Board annually? I would only like to send it to the Board if changes are made, such as a change in the CRA Officer.
Posted By: MScarn6942
Re: CRA policy - 03/14/19 05:11 PM
I wouldn't include the specific name of the CRA Officer in the CRA Policy. Just say you'll appoint one. I'm not sure on approval.
Our CRA Policy is approved at least annually by the board.
Just my two cents on board approval of policies... They don't read those things. They couldn't score 20% on a quiz covering the content of X policy.
The prevalence of policies being approved by boards, in my opinion, is far too much.
Posted By: Mel in WA
Re: CRA policy - 03/14/19 11:41 PM
Norman Paperman.....I couldn't agree more! That's why I'm re-analyzing this whole activity trap. What really needs to be approved and how often. If anyone has a list, please share.
Posted By: CRAWilson
Re: CRA policy - 03/15/19 02:43 PM
My firm has a CRA Statement.