Community banks face challenges meeting regulatory requirements. With rule changes and staff turnover, it can be difficult to determine the best path forward for your bank to fulfill community reinvestment goals and obligations, track them, and clearly communicate value to examiners. Our CRA Support Services can help bridge any gaps your bank may be facing and optimize your compliance efforts.
Self-Assessment
Conduct review of assessment area demographics, lending, branching, and Community Development activities
Develop performance context to include mitigating factors related to perceived deficiencies in performance
Provide detailed, written assessment following FFIEC CRA Exam Procedures (appropriate for your bank)
Assessment Area Analysis
Evaluate delineated assessment areas to determine appropriateness
Branch Distribution Analysis
Determine any issues with branch distribution relative to serving low- and moderate-income people and geographies
Peer Analysis
Determine bank “peers” for comparative purposes
Community Development Activity Evaluation
Review and evaluate loans, investments, donations, and services to determine CRA qualification as well as community impact
Ensure documentation and description demonstrates qualification and impact
Strategic Plan Development
Determine appropriateness of Strategic Plan option
Solicit public comments
Develop or update CRA Strategic Plan
CRA Action Plan
Help establish a meaningful and targeted approach to improving CRA performance at the institution, state, and product levels based on either self-identified deficiencies or less than satisfactory exam ratings
CRA Compliance Program Review
Review overall CRA program, including management reporting, goals, and deficiencies
Provide tangible recommendations for program enhancement
Provide action plan for implementing targeted results
CRA Ratings Appeal
Challenge CRA rating of “Needs to Improve” or “Substantial Noncompliance” within your regulator’s challenge criteria