TO ALL CRA OFFICERS: BLESS YOUR HEART! By Steffani Jenkins, CRA Liaison, ICBA CRA Solutions Have you ever been told “Bless your heart!” after talking about a challenging situation? Being from the South, this is what comes to mind when a banker tells me they’ve just been gifted with the title of “CRA Officer,” along with all their other responsibilities. CRA requirements and compliance are evolving; therefore, learning the basics of CRA is critical. If your bank is an HMDA and/or small business reporter, the first thing your examiner will typically do at the onset of a CRA exam is perform a data integrity review of your HMDA LAR and your small business loans. If your error percentage is above 5%, this sets the stage for the CRA exam and … bless your heart! It’s probably not going to go well. Review every loan to ensure the loan is coded correctly and that all reportable fields for CRA match the application or other supporting documentation. Depending on the volume of loans, this could be a full-time job, but the results are worth the money and effort to ensure your data is accurate. Most intermediate-small and large banks are required to report their Community Development activities for consideration by their regulator at exam time. The big question is always “How much is enough?” Your last Performance Evaluation (PE) should be a good indicator. If they used words like “poor” or “adequate,” you need to step up your game. Set goals for each assessment area 14 The CommunityBanker
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