Episode 70: CRA Services: If It’s Not Documented, It Didn’t Happen
CRA Services: If It’s Not Documented, It Didn’t Happen

Episode 70: CRA Services: If It’s Not Documented, It Didn’t Happen

I received an email from a CRA officer who recently took over a CRA program. Although this individual is a seasoned compliance professional, she’s new at running a CRA program, and the exam was right around the corner. Here, I share her journey and tips to document community development activities. 
When it comes to community development services documentation, there isn’t a one-size-fits-all solution. Many of our bankers will use various annual reports, tax returns, and even websites to gather the information they need. I recommended that this CRA officer go back and embed a process, so she gets what she needs to prove the primary purpose of community development. 
This helps when time is of the essence and you need to pull information together quickly. Shoring up your program prevents scrambling at the last minute. When we get that notice of the CRA exam, proper documentation can be a lifesaver. 

Interagency Questions & Answers Regarding Community Reinvestment (Questions and Answers) were released by the staffs of the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the Currency on July 15, 2016, to provide guidance to financial institutions and the public.

Guidestar.org is also a good resource to learn more about nonprofit organizations, their mission, and even review their IRS Form 990 (their version of a tax return).
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