#073: CRA Tips: I'm an ISB, do I really need to look at my lending performance?
Update: 2023-08-29
Description
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’t required to report, it’s important for you to know what your performance is before the examiners. Pulling your data on at least an annual basis and reflecting on some of the key performance standards is highly recommended.
A Banker’s Quick Reference Guide to CRA, Federal Reserve Bank of Dallas: https://www.dallasfed.org/~/media/documents/cd/pubs/quickref.pdf
CRA Today Website: https://cratoday.com/
CRA Hub: https://cratoday.com/hub
Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/
Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)
All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.
This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.
Here, I outline the best practices I shared in response to this question. Although ISBs aren’t required to report, it’s important for you to know what your performance is before the examiners. Pulling your data on at least an annual basis and reflecting on some of the key performance standards is highly recommended.
A Banker’s Quick Reference Guide to CRA, Federal Reserve Bank of Dallas: https://www.dallasfed.org/~/media/documents/cd/pubs/quickref.pdf
CRA Today Website: https://cratoday.com/
CRA Hub: https://cratoday.com/hub
Linda Ezuka, LinkedIn https://www.linkedin.com/in/linda-ezuka-cra-today/
Copyright © 2023 by CRA Today LLC(No claim to original U.S. government material)
All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.
This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.
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