Examiner Tips and Sound Practices

Community Development

  • Read local revitalization plans to learn about community needs from those that are most familiar with the needs
  • Develop a peer analysis of similarly situated institutions to identify opportunities you may not be aware of
  • Develop relationships with community groups and community development (CD) practitioners to learn about the needs/opportunities with those who have the "boots on the ground."
  • Match activities to CRA objectives to highlight the bank's ability to meet the needs most in demand
  • Document the impact of activities (e.g., number of jobs created or low- or moderate-income individuals benefitting) to highlight responsiveness

CRA Program/Examination Readiness

  • Track CD activities on an ongoing basis; credit cannot be given if examiners are not aware of activities
  • Document qualifying aspects of a community development activity
  • Provide summaries of donation grantees or organizations in which employees are involved
  • Prepare a qualitative analysis of the bank's "CRA Story" to share with examiners
  • Ensure all bank employees are aware of how their job could impact the bank's CRA performance
  • Evaluate and strengthen any CRA program inefficiencies identified during the last CRA exam

Common Examination Issues

  • Lack of supporting documentation to help examiners qualify CD activities
  • Not communicating important performance context factors or qualitative considerations for CD activities
  • Under reporting of community development loans