CRA policy

Posted By: Compliance Action Subscriber 1226

CRA policy - 02/13/17 09:16 PM

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: Compliance Action Subscriber 1226

Re: CRA policy - 02/15/17 03:24 PM

OK thank you
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.
Posted By: JWills, CRCM

Re: CRA policy - 03/14/19 08:07 PM

Our CRA Policy is approved at least annually by the board.
Posted By: Norman Paperman

Re: CRA policy - 03/14/19 08:38 PM

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.