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