What was your last CRA exam like? Did it run perfectly smoothly? Did you hand your CRA examiners your self-assessment, shake hands, and tell them you’ll see them next exam?
Probably not. Chances are it was a hectic week of pulling reports, responding to questions, pulling more reports, scheduling meetings, finding a different room with more privacy, and, and, and… all while you were trying to work on your everyday tasks.
If your exam was anything other than a thanks and a handshake, you should consider appointing a CRA exam liaison.
A CRA exam liaison plays a critical role in the regulatory exam process. Exam time is usually hectic and stressful, and may be even more so if your upcoming exam is remote. As much as you may anticipate your examiners’ needs and prepare your CRA self-assessment, there will always be more to do and more questions to address. By appointing a dedicated CRA exam liaison you’ll have someone on point who can manage your exam at a high level, giving you peace of mind and taking care of the small details. Now your CRA examiners can concentrate on the outstanding community impact your bank has had over the last few years and not worry about bothering you with questions.
The duties of your CRA exam liaison can be as wide or narrow as you like. The main thing to remember is that your CRA exam liaison is the examiners’ primary point of contact. All questions from the examiners should be directed to your CRA exam liaison, who will then reach out to others for answers and bring concerns to the correct area. This means your examiners won’t have to interrupt their review to gather any additional clarifications they need.
At a minimum, you’ll want someone who can prioritize CRA exam related tasks over other work while your exam is underway. It’s important to choose a CRA exam liaison who is also organized, proactive, and familiar with your CRA program, your bank, and your local area. For small banks, the best choice for a CRA exam liaison may be the CRA Officer or a member of the compliance team. Larger banks may have a dedicated position for the CRA exam liaison.
The role of a CRA exam liaison begins before the exam and continues through its conclusion. Before your exam, a CRA exam liaison can begin preparing the information and documents your examiners need. A good liaison doesn’t just fulfill the basic logistics, but also shows your examiners that you have a professional, well-run CRA program.
Before the exam, your liaison can begin gathering everything your examiners will need for their evaluation:
- All requested information within the Compliance Information and Document Request (CIDR)
- A copy of your self-assessment, if you have one
- A list of key community partners you’ve worked with so they can choose their community contacts
- Meetings with key partners or bank employees who are key to your CRA program
If your exam will be onsite, this also means preparing workspaces and local area information. Key items to arrange include:
- Reserving a private room with plenty of table space, space to social distance as needed, power outlets, and access to restrooms
- Information about parking and good local restaurants close to your site
- Information about your area’s COVID restrictions, such as the most recent local guidance on mask restrictions, if any
Good communication will be even more critical for remote exams. If you think you may have a remote CRA exam (and many will), your CRA exam liaison should schedule a weekly Zoom meeting to track progress and answer any of the examiners’ questions.
When you anticipate their needs, your examiners will be stress-free and ready to review your program. And a stress-free examiner will be able to see more of the positive aspects of your CRA program.
Once examiners are on site, the CRA exam liaison will kick into full gear. The liaison should be on site to meet your examiners, give them a tour of your facility, and show them to their work space or arrange an introductory Zoom call. The CRA exam liaison will be your examiners first point of contact and should be easily available either through virtual contact or close proximity. During the exam period, the liaison may be called on to schedule additional meetings, pull additional reports, or provide more detailed information on certain CRA activities. It isn’t necessary for the CRA liaison to know all the answers, but the liaison must know where to find them and who to contact for each report or program activity.
A CRA liaison can be the difference between a confusing, hectic CRA exam and a smooth, focused CRA exam that results in the rating you want. You can start preparing now by finding out when your next exam is scheduled and getting familiar with CRA exam procedures.
If you want to learn more about CRA exam best practices, join us in October for our Exam Prep Workshop.
- 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