I relatively recently took a position as CEO with a small community bank ($45 million). Formerly, I was President of a $450 million bank. Needless to say, at a smaller institution, we all wear many hats. One of mine is CRA Officer and, since I had a dedicated person before, I'm rusty. I just read your entire section on the CRA regs. I want to be sure I'm not missing anything. As a small bank, is it really true that our total evaluation will be based solely on loan to deposit ratio, having the majority of our lending within our assessment area, reasonable distribution to low to moderate income individuals/families, reasonabel geographic distribution within our assessment area and prompt corrective action to any complaints? Is that really all? And, if we were graded "satisfactory" on those 5 elements, we'd have a crack at an "outstanding"? Small banks may elect to be evaluated on the lending, investment, service tests. Why would a bank want to do this if, as a small bank, they can elect to only be graded on those five areas? Ditto for submitting a Strategic Plan? Is there any benefit to a small bank in electing to be graded on either of these other two options? If, as we do, have a significant level of "service" and "investment" activities, do these get evaluated at all if we ultimately elect to be evaluated as a small bank? Can you give me some concrete examples of "Investments"? We currently participate in a local CEDE (Center for Economic Development) organization and are also involved in several minority organizations (Washtenaw County Homebuyers, POWER) with board positions, loans, agreeing to accept IDA's, participating in financial education seminars . . . are all those activities considered "Investment" activitiesor are there others I'm not recognizing? Other than the five elements of evaluation for a small bank, am I missing any other significant difference between how we would be evaluated and how a bank over 250 million would be evaluated? There seemed to be some di!fferences in data collection . . .please elaborate. Also, our bank is an 80% owner in a mortgage sub servicing company located in the Upper Peninsula of Michigan (we are in Ann Arbor)and that subsidiary also engages in originations. What kind of reporting do we need to be concerned about with the sub, if any, since all loans are sold into the secondary market? I thank you in advance for guidance and elaboration on this so I can relaunch our compliance with the CRA correctly for our small bank.
We're looking for something really different to get our bank noticed. We're in a fairly small community that is close to being overbanked. How do we make ourselves stand out from the crowd?
Help! We just crossed the magic threshold of having 50 employees. I am told this makes us subject to the affirmative action laws and requirements. Are there some common mistakes that companies typically make in the affirmative action area? We don't want to get nailed.
One of your loan customers has been in default for months. You have given all the proper notices and have been trying to locate your collateral, vending machines and other office equipment for over sixty days. A former employee has just informed you of the location of a warehouse which contains the equipment. You make arrangements with the owner of the building to pick up you collateral. Today the bank received notice of your customer's bankruptcy which was filed last week. You want to retrieve the equipment and hold it for the trustee. Is this action permitted under the Bankruptcy Code?