support community development activities. In some markets, these changes
could lead to a vacuum for you to exploit.
A visit to your state’s website can point you toward programs that might
fit into your CRA plans. On a more local level, search websites of counties
and municipalities in your assessment area for mention of Enterprise Communities, Empowerment Zones, Tax Increment Financing (TIF) zones or
similar areas that have been targeted for economic revitalization. They may
suggest opportunities that may pay off in CRA credits. Also, consider starting
a working group within your organization. Some banks will create an official
“CRA Committee” while others will make it more informal. In short, this will
be a body of those business units responsible for generating the loans that will
be evaluated for mortgage, small business, or community development. It
can include those responsible for making CRA-related investments, product
innovation or branch distribution decisions, and anyone else beneficial to
the discussion. You may want to include compliance, legal, or underwriting
teams as regular members or adjunct team members for specific concerns.
Keeping everyone throughout your organization apprised can help alleviate
surprises following a CRA examination.
You should also set goals and measure your performance against those
goals. You may wish to meet in small groups to work out action plans when
you aren’t meeting your CRA goals. You may need to think of how to escalate
concerns when you aren’t getting traction, and how to celebrate successes
between CRA examinations.
Originating activities that support CRA is a never-ending cycle. And, there
are many external resources that can help you prepare for uncertainly, also.
(See the adjacent sidebar on “CRA Prep Resources”.) Just be sure that while
you are evaluating CRA performance and communicating results—have fun!
Work in the area of CRA is a big job, but it is meaningful and rewarding as
you see the impact on communities over time. ■
1 Banks are governed by 12 CFR Part 25 (Office of the Comptroller of the Currency–OCC
for National Banks), 195 (OCC for Federal Savings Associations), 228 (Federal Reserve
Board—FRB), or 345 (Federal Deposit Insurance Corporation—FDIC
ABOUT THE AUTHORS
PAUL J. JAROSZ, CRCM, is the Compliance/CRA officer for a community bank
based in the western suburbs of Chicago. He is responsible for overseeing all
aspects of the bank’s regulatory compliance program, including the letters
CRA, HMDA, and BSA. He has 30+ years of compliance-related experience and
has held similar positions in institutions ranging from other small community
banks to a large multi-state banking organization.
Paul is also the founder and chair of CRA NOW, a networking organization
for Chicagoland CRA Officers—meetings focus on CRA, HMDA, fair lending and
other compliance topics. Paul can be reached at email@example.com.
JAN E. WOOLSEY, CRCM, retired in 2017 after nearly 20 years of managing the
CRA program at MUFG Union Bank, and often describes herself and her team as
the “CRA conscience” or “scorekeeper” for the bank. She is a passionate advocate
for pushing the envelope in support of low- and moderate-income communities. Jan worked with industry leaders, as well as the Interagency Task Force, to
help shape the regulatory interpretive guidance to give more clarity to the CRA
regulation, and to balance the benefit to LMI individuals and families. Since her
retirement, she has returned to her CRA roots as a consultant, and looks forward
to the CRA modernization ahead. She can be reached at firstname.lastname@example.org.
“To expect the unexpected shows a thoroughly
modern intellect” —Oscar Wilde
There are many available resources that can
prepare you for what’s to come:
■ ■ ■ Go straight to the source—the regulation and FAQ’s. The
FFIEC CRA webpage should be on your URL favorites list:
■ ■ ■ Check out your peers’ Performance Evaluations (PEs) to
see how you’re doing and for ideas for improvement. The
FFIEC offers an interagency Rating Search, www.ffiec.
gov/craratings/ default.aspx, which can be very useful in
determining which of your peers you want to study further.
Each of the prudential regulators offers a search engine to
pull up the PEs that they have issued:
• FDIC: apps.occ.gov/crasearch/default.aspx
• FRB: www.federalreserve.gov/apps/crape/BankRating.
• OCC: apps.occ.gov/crasearch/default.aspx
■ ■ ■ Email updates. Watching out for communications from your
regulator is a given, but sometimes the earliest notices are
from vendors touting their response to upcoming changes.
■ ■ ■ Submit comments on any proposed changes. Visit www.
tips on writing an effective comment letter.
■ ■ ■ Another great resource of upcoming changes is the ABA
Bank Compliance magazine. There is also a Regulatory
Developments Table at the end of each issue. Or, visit
ABA’s members only CRA resources page at aba.com/
■ ■ ■ When in doubt, contact your local examiner or Community
Affairs Officer for counsel. In the case of larger banks,
you may have a dedicated CRA examiner and may be
able to establish regular ongoing meetings throughout
your examination period, making the examination itself go
■ ■ ■ Attend seminars/conferences, whenever your training
budget allows for it. Mark your calendar for the biennial
Interagency CRA conference, and look for invitations to
vendor seminars, as well as trade association meetings and
schools that focus on CRA or fair lending topics.
■ ■ ■ Developing a network of CRA peers to bounce off ideas.
Join a CRA networking group in your area; if there is none,
start one. In some of the larger markets, the regulators will
host periodic CRA Roundtables with interesting discussion
topics. Often these meetings are free or have a very low
cost to participate. Check with your regulator to ask whether
there is something similar for your region.