As most of you know, the public file is a straightforward requirement of the CRA. Its purpose is to disclose basic information about your bank, its products and services, and how you serve the community. The file includes a wide variety of information, and here I discuss the technical requirements, what not to include, and recommendations around best practices. Tips include putting together a checklist so you don’t miss any necessary requirements. I also go over additional information you should make available to the public, the two typical versions of a public file, how to handle requests fo ..read more

On October 12, 2023, we marked the 46th anniversary of the CRA. As we reflect on the past, I challenge you to consider your role in extending opportunity within your community. Here, I share a special message with our bankers who are forging an impact in our local communities. I also share a personal story about how my mother received an opportunity that changed our lives forever. While we all have different opinions on these regulations, it’s still a beautiful opportunity to change people’s lives and leverage capital for the greater good. Many come to CRA today looking to uplevel their progr ..read more

In a recent CRA fundamentals office hours session, we discussed current practices around community development services. One bank professional asked why, at her last bank, they counted the number of hours of qualified community development services, but at her current bank, they count both the number of occurrences and hours. Both of those banks were FDIC regulated. In the past, I was with an FDIC bank, and we counted services by hours. If you’re confused, you’re not alone. Here, I explain how to look at your bank’s performance evaluation and past exams for context. I also talk about how to t ..read more

In a recent webinar, I received some great tips from a panel of women who shared their journeys in leading their CRA program. I was inspired to pass them along here and share the importance of building a solid team around you in your own program. I start with a story about a private client who had to pull together her own team and the challenges that she faced. I share the three lines of defense CRA officers should put into place and the importance of reflecting on the current state of your CRA program. I also discuss why running a CRA program is like a relay, why charitable donations to mar ..read more

In case you missed it, I recently published an article in the ABA Compliance Magazine earlier this year. It was all about preparing for your CRA exam in the midst of regulatory uncertainty. We sure do have a lot of uncertainty swirling around these days. Although it’s easy to get distracted, I recommend you stay laser-focused on your CRA program and finish strong with your current exam cycle. Your bank will likely have one more exam under the current rules-do you know where your strengths and gaps are in each of your assessment areas? Here, I provide a couple of suggestions on how to prepare ..read more

Sarah Hope Marshall joins me here to reflect upon digital inequity in place-based community revitalization. Our discussion focuses on digital inequity and how community development professionals can revisit this as they revisit their community development programs. Here are some key quotes from our conversation: “It made me pause and ask, wait a minute. This neighborhood that we’re in has a really rich history of community organizing and groups working together. There’s been books written about it. In my research, I’d done work studying the first-ever tenant buyout of a HUD affordable buildin ..read more

Your previous CRA exam may not have included pandemic activities, but your next one is likely to include activity around the SBA’s Paycheck Protection Program, or PPP. You can get credit for participating in the PPP under your CRA program, which translates into CRA lending performance. Your next exam would highlight your participation in the program, and you would also account for the individual loans that were deployed under the program, either as small business lending performance or community development loan activities. Here, I share how to classify these PPP loans and how to tell if your ..read more

Recently, I was approached by a CRA professional in the industry who was about to be examined. They were working on compiling all their community development loans, and they got a bit turned around when reviewing their loans to nonprofit organizations as asked for guidance. I advise bankers to conduct a 100% review of a bank’s loans to nonprofit organizations due to the charitable nature of the nonprofit entities. This doesn’t guarantee community development qualification but I find many of these loans are prospects to dig deeper into. In this episode, I break down each community development ..read more

I recently received a question from someone newer to the CRA within an intermediate small bank (ISB). They knew they didn’t have to report their lending data but wanted to know if they needed to actually review it. Additionally, if they did need to review it, they wanted to know how they would do so. I referred them to the Banker’s Quick Reference Guide I’ve linked below. It’s one of my favorites because it’s a quick review of all performance standards and shows you how examiners evaluate performance. Here, I outline the best practices I shared in response to this question. Although ISBs aren ..read more

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