CRA is an important consideration in any regulatory application, including mergers, acquisitions and new branches. In addition, the Gramm-Leach-Bliley Act emphasizes the importance of a bank's CRA performance in determining which banks will be permitted to expand their business beyond normal bank activities. We can help you monitor your performance periodically and make adjustments to address any deficiencies.
Performance Evaluations: Our staff of compliance professionals has specific experience with regulatory expectations for CRA performance in all types of institutions – small and large banks, limited purpose banks, and wholesale banks. In completing the CRA performance assessment, we will: |
- Evaluate CRA performance in accordance with Interagency Examination Procedures
- Update the performance context with changes since the last examination
- Determine if the assessment area conforms with regulatory requirements
- Assess lending performance in the home mortgage, small business, and consumer loan portfolios
- Review qualified investments, grants, and donations
- Analyze retail banking and community development services
- Utilize mapping software to portray the financial institution's assessment area and lending performance
- Review compliance with the technical requirements of CRA
- Prepare a written report for management
- Recommend CRA strategies for future performance
- Meet with the regulatory examiners to discuss our evaluation
- Provide quarterly updates of CRA performance
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Data Collection & Reporting: We will evaluate the current HMDA and CRA reporting process and determine the most efficient data collection and reporting procedures. We are also available to administer the data collection process to ensure accurate and timely filing by: |
- Implementing the data collection and reporting process
- Testing the integrity of the HMDA and CRA data on a quarterly basis
- Preparing the HMDA and CRA data for submission
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- Strategic Planning
- Protested Applications
- Training
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