Episode 46: What exactly is the BLS and how does it relate to the CRA?
So many of you have asked “what exactly is BLS (hint, it is the Bureau of Labor Statistics) and how should I use it to support my CRA program?” Well this month in the CRA Hub, we’re focusing on CRA exam prep. As you know, it’s really important to make sure that we are crossing our T’s and dotting our I’s and making sure that all of our community development activities are properly documented.
Episode 45: How to Leverage Internal Expertise to Drive External Impact
Are you looking to take your community development services to the next level? If so, don’t underestimate the breadth and depth of internal expertise that lies right at your fingertips. Your bank is likely full of subject-matter experts that can enhance your existing services or perhaps even build out an entirely new external partnership.
Episode 44: Economic Development as a Key to Community Development Services
There are a wealth of opportunities to serve aspiring entrepreneurs and established small businesses!
Episode 43: How to Increase your CRA Services By Partnering with Impactful Organizations
After collecting information about existing employee involvement through board service and volunteerism, it’s apparent you need to increase your bank’s community development services…but where do you start?
Episode 42: I Bet You Are Underreporting Your Community Development Loans… Most Banks Are Too!
I predict that at least 90% of banks under report their community development loans. Yes, that’s an alarming statistic, but I believe it’s true. As I often say, the art of the CRA is not creating new programs, but actually unveiling what your bank is already doing to meet the needs of your community by the nature of opening your doors and deploying your core banking services.
Episode 41: Key Departments Critical to A Sound CRA Training Program
A key element of your CRA program is understanding that CRA is not always about creating new opportunities, but is about finding the opportunities that already exist. To do this, you should aim to give each team at least three CRA trainings a year. This will keep team members up-to-date on any new regulations and will help keep your program top of mind. Team members are more likely to forget about CRA when they haven’t heard from you in a long time. But if you train team members to watch out for CRA opportunities, you’re almost guaranteed to come across new services, loans, and investments that are eligible for CRA credit.
Episode 40: It’s National Financial Capability Month…Where Do I Begin?
April 1st marked the start of National Financial Capability Month, a month during which organizations (especially financial institutions!) across the country focus on supporting programs that expand financial literacy, economic empowerment, and access to capital and credit for all consumers.
Episode 39: CRA Plan Checklist Inside!
It’s time to build your 2022 CRA strategy and action plan! Here are your next steps…
Episode 38: Haven’t Developed a CRA Plan Yet?
Build your CRA plan.You aren’t required under the Community Reinvestment Act to build a plan, but it’s an industry best-practice and will help take your CRA program to the next level. Keep your plan simple and don’t worry about making it perfect. Your plan can be one page or it can be 20; everything is up to you.
Episode 37: Congrats! Take The Day Off!!
Data submitted…now what? Now that you are confident in the reliability of the data, revisit your goals for the new performance year. It’s never-ending, I know!
Episode 36: Just 120 Business Hours Left…
Why does February only have 28 days? It seems so wrong as we are up against our March 1st CRA data reporting deadline!
Episode 35: Just 10 Business Days Left…
As you know, time is ticking away and soon you will be faced with scrubbing your CRA data to ready your small business, HMDA and community development loans data submission. Over the next few weeks, we will cover the most common mistakes and will provide some guidance to support you on your road to CRA data integrity.
Episode 34: You Only Have Three Weeks Left…
Let’s refocus our time on your CRA data integrity and, for some of you, your annual CRA data submission.
Episode 33: Three Ways to Supplement Your CRA Program Today
Let’s say you don’t get to add to your CRA staff. What can you do to accomplish all of the work that you have before you? Today, I have three ways to support and supplement your CRA program.
Episode 32: How to Build the Culture of Compliance Within the Bank
So, how do you actually build the culture of compliance within your bank?
Episode 32: How to Build the Culture of Compliance Within the Bank
So, how do you actually build the culture of compliance within your bank?
Episode 31: How to Add a Team Member to Your CRA Mighty Team of One
So, how do you best go about dividing and conquering the work of a CRA officer? Many people inherit the CRA program and still have compliance responsibilities or dabble in BSA or share the titles of CRA officer and fair lending officer.
Episode 30: How to Grow Your Team Without Adding Staff
Let’s say you can’t “add to staff” given resource constraints and you have to remain a mighty team of one doing “all of the things.” Sometimes you might feel like throwing in the towel…but not so fast! I have a few ideas for you.
Episode 29: How to Do the Undoable Deal
We spent the last few CRA tips talking about community development finance. Today’s episode focuses on filling the gap when a seemingly undoable deal is before you.
Episode 28: It Takes a Village…Do You Know Who You Can Trust?
The best and most impactful community development finance projects are not done by any one bank, CDFI or community partner. The most monumental community-based projects are forged over time with strong leadership (and trust!) and the fortitude to manage the never-ending variables that are often required when driving impact into the most disadvantaged communities.
Episode 27: Community Development Finance: Yes, It’s Part of Your Job Too!
Once you have a good understanding of the technical aspects of the CRA and have stabilized your CRA program, now it’s time to expand your reach into the community. Oftentimes, that will involve working alongside various stakeholders, who care deeply about serving lower income and disadvantaged communities.
Episode 26: I Failed My CRA Data Integrity Exam – Now What?
Take a deep breath. There is life after a failed CRA data integrity exam. I’ve been through a few rough ones over the past 27 years, and every bank ends up with a stronger program as a result. While I can’t promise a smooth path forward, I can offer a few quick tips to help you get to the root cause.
Episode 25: Best Practices to Ensure CRA Data Integrity
Gather all of your data-related resources into one place.Review the data-related policies and procedures. Review the content. What is missing? Is it accurate? When was it reviewed last? Does it have a revision date?
Episode 24: The Secret to a Smooth CRA Data Integrity Exam!
I bet you, you didn’t guess this one! The secret to a smooth CRA data integrity exam is your loan operations team! Yep, loan ops! Wait what?
Episode 23: How to Ace Your Next CRA Data Integrity Exam!
As you know, before each exam, your regulators will conduct a review of your lending data to ensure that it is accurate enough to be relied upon to determine your lending performance. The regulators have a very specific approach that is delineated within the Consumer Compliance Handbook.
Episode 22: The Devil Is in the Details but Don’t Let It Get to Your Data, Too!
The purpose of CRA data collection and maintenance is to enable examiners and the public to evaluate (through issuance of a CRA Performance Evaluation) whether a bank is helping to meet the credit needs of its communities through its small business and small farm loans. Accurate data leads to accurate assessments of fair lending and CRA lending performance. The bank is subject to reputational risk due to data errors that may lead to costly remediation and erode consumer confidence.
Episode 21: Creative Items to Add to Your CRA Committee Meeting Agenda
Are you looking for creative ways to reinvigorate your CRA committee meetings?
It is crucial to foster communication and collaboration during these meetings, so people leave inspired and are motivated to get involved in your CRA program. But, this is easier said than done.
Episode 20: Three Documents You Must Have for Your CRA Program
When it comes to CRA program governance, there are three documents that every CRA program should have: a CRA policy, a CRA program plan and a CRA self-assessment.
The CRA Policy: This document explains what you stand for, how you run your CRA program from the highest level, and how the program fits into your overall governance.
Episode 19: Repurpose Your CRA Self Assessment To Build Awareness and Buy-In
Once you have a solid self-assessment document, now it is time to socialize it. Not only will you increase awareness of your CRA program, but you will also be using it as a training tool. Make sure you break it down to the discrete applicable parts to avoid overwhelm.
Episode 18: Five Key Resources To Inform Your CRA Self Assessment
Does a blank page make you nervous? Yes, us too.
Here are some documents you may want to reference (and even borrow the framework of!) to get you started on your CRA self assessment.
Episode 17: Choices. Make One and Let’s Get to Work!
There just aren’t enough hours in the day. We get it. Many institutions believe they don’t have time to perform a self-assessment. What you may not know is that there are many types of self-assessments, some easier than others. Check out this list of assessment types to determine what kind of assessment will best fit your institution’s needs. Having a CRA self assessment is a best practice and a must have.
Episode 16: Look Back to Learn How to Look Forward
Many banks make the mistake of spending too much time over-analyzing their performance history without giving equal airtime to formulating new strategies to address performance gaps within their CRA programs.
Episode 15: Strategy Is a Commodity, Execution Is an Art
Do you know what your bank’s strategy is? If this is not something that has been shared with you, reach out to leaders within your organization’s hierarchy to learn more. Ask questions like, “What are your division’s key priorities?” and/or “What is the major initiative you are focusing on this year?” Take this information and brainstorm ways that you can align their strategies and initiatives with your CRA program priorities.
Episode 14: Don’t Leave This for the Examiners to Decide
The single most important CRA exam prep tool for you to consider is a CRA self-assessment.
CRA self-assessments are assessments you perform on your own institution to understand your CRA strengths and performance gaps. If done correctly, the self-assessment mirrors an examiner’s approach to assessing your performance under the CRA. This assessment helps you understand how you’re currently performing, so you can prepare your performance context and story for your next CRA examination.
Episode 13: CDFIs Are Changing The World. Will You Join Them?
Community Development Financial Institutions (CDFIs) were created to deliver responsible, affordable lending to help low-income, low-wealth and other disadvantaged people and communities join the economic mainstream.
Episode 12: $2.2 Billion Is at Stake for Low-Income Taxpayers
Join the network of thousands of volunteers that ensures millions of low-income taxpayers receive billions of dollars in refunds, a network that helps the community meet their civic obligations as taxpayers and supports them on the path to financial security and opportunity.
Episode 11: The Average American Has $90,460 In Consumer Debt
According to Experian data, if you have a credit card or two in your wallet, you’re not alone. There is over $756 billion in outstanding credit card debt in the U.S., and approximately 95% of adults have a credit card account open in their name, according to Experian data from the third quarter (Q3) of 2020.
Episode 10: One Super Simple Community Development Service You Might Be Under-Reporting
The low-hanging fruit of community development services is…boards and committees!
Many bank executives and employees are or could be serving on nonprofit boards and committees. These service hours and activities count towards the majority of community development services for most banks.
Episode 9: Can the Countless Hours We Spent on the SBA PPP Count? You Might Be Surprised…
Can the countless hours you’ve spent on the SBA Paycheck Protection Program (PPP) count as a community development service?
The answer is yes and no! Although your bank worked seemingly around the clock last year to stand up the SBA PPP, none of the hours spent internally creating the loan application portals, working on underwriting and compliance or deploying loans under the program count towards your CRA program.
Episode 8: Three Community Development Services You’d Be Surprised Don’t Count
On this week’s CRA Tip episode, we explore three community development services you might be surprised don’t count as CRA activities. Here is a brief overview:
Episode 7: Are You Unintentionally Under-Serving Low- and Moderate-Income (LMI) Communities?
Take a second look at the retail distribution of your branches, ATMs and deposit-taking ATMs. Sometimes, it is helpful to map these data points to visualize how far away your branches and ATMs are from the next closest low- or moderate-income area. Now that you’re looking more closely, does your retail distribution arbitrarily exclude LMI geographies?
Episode 6: Three Ways To Inspire More Community Development Loan Activities
Last week, we talked about community development loan identification best practices – the low-hanging fruit that may already exist at your institution.
Now, we switch our attention to proactive measures! Here are some best practices to increase the number of community development loan prospects that come across your desk.
Episode 5: Internal Stakeholders: Who They Are And Why They Matter
You can’t do this work alone. In fact, the best CRA programs are built around key stakeholders working together towards the same CRA goals.
As you know, mining for community development loans (CDL) can be a very manual and time-consuming process. This is especially true given that the subjective and technical definitions of a CDL aren’t often necessary within each credit approval memorandum write-up.
Episode 4: Community Development Loans… How Much Is Enough?
Regulators are currently revisiting the way they define a community development loan (CDL) through CRA modernization efforts. So until there is more regulatory certainty, how do you determine how many CDL qualified loans are enough? While you can’t guarantee anything during the iterative swirl of CRA reform, this episode aims to give you a good idea of reasonable targets when executive management asks “how much is enough.” Here’s where you should start:
Episode 3: Community Development Loan Mining Strategies You Don’t Want To Miss
When looking through your loan portfolio for qualified community development loans, it is essential to have a strategic approach given limited time and resources to conduct a 100% review. A tactical approach can save you time and help you qualify more loans to support your bank’s lending performance.
Episode 2: Five Must Have Strategy and Implementation Documents to Guide Your CRA Program
As you start building or refreshing your CRA program, these internal documents can serve as a guiding light. Gather these core documents and make sure you revisit them often as you initiate new programs and build your CRA culture throughout the bank.
Episode 1: CRA TIPS – A Series Created for CRA Practitioners
Managing the Community Reinvestment Act (CRA) program for your financial institution can be challenging, especially if you’re new to the CRA. To support you in your CRA journey, CRA Today and Kadince have partnered to provide informative content to highlight CRA best practices and ideas to guide your CRA program.
- Finish Strong, as published in ABA Bank Compliance - December 31, 2022
- What’s a Capital Stack and How Does it Work? - November 18, 2021
- The CRA Tips - October 21, 2021