It’s A New Year – Time to Prepare for Your Next CRA Examination
Written by: Bill Dolan, CMB, AMP
The question is simple. Are you and your compliance management team prepared to tell your story? Face it, there is no one more adept at devising your story and clarifying your performance to examiners than you, especially addressing the following:
Gathering performance context data
Reviewing your strategy and goals
Documenting your processes
Reviewing, updating, and organizing your public files
Testing the integrity of your data (sampling and comparing to your source data)
Analyzing your data
When it comes to CRA compliance, believe me, there is no “magic” bullet. To help ensure success with your CRA examination, your CRA strategy must align both your products and services to just what your community’s needs are. Your CRA strategic plan should help your institution better serve your community, build internal support for CRA compliance, improve your compliance exam ratings, and most of all, help your financial institution grow.
Whether the Federal Reserve Board, FDIC, NCUA, OCC, CFPB, or any regulator or examiner will tell you, that “developing a CRA strategic plan, setting your institution’s goals, and monitoring the results can definitely make CRA performance more predictable and more meaningful.”
At Spillane Consulting Associates, our team of seasoned expert consultants (former regulators, examiners, compliance directors and lenders such as yourself), can help you to think through your approach and help you succeed in the areas of assessment reviews, the analysis of your market lending data, reviewing mapped data to determine market performance, branch location analysis, reviewing lending performance to your set benchmarks, and examining lending test ratios (i.e. in/out ratios). These are just a few of the ways that SCA can help you succeed with your CRA.
Contact Bill Dolan, Director, at (617) 694-2617 or by email at: Wdolan@scapartnering.com to begin preparing and managing your CRA strategy for your next successful CRA examination.
