Who is responsible for y our CRA Program?

If you said “the CRA Officer,” I want to challenge your thinking on that. You should consider your bank’s CRA program to be the responsibility of every employee in your company, from the tellers on the bank floor to the back office employees and all the way up to the highest executives. Everyone in your financial institution should recognize the value the CRA program brings to your bank and your community. They should all be inspired to be an active part of it. And YOU can make that happen. You just have to create a culture of compliance. Here’s a glimpse into how to do that.

Your CRA Program is a lot for any one person to tackle for any bank, large or small, but you don’t have to do this alone. You have hundreds, or maybe even thousands, of people at your bank who can serve the community. In fact, many of them may be actively serving the community right now in ways that would bolster your CRA program or help you identify more opportunities for your bank. While many bankers and non-bankers have heard about CRA, very few bankers understand their role and what they can do to improve their bank’s rating. Your internal CRA Training program can help.

Everyone Can Contribute to the CRA Program

An internal CRA Training program can increase your reach in the community in ways you might never have thought about. You may have employees working with schools, churches, and non-profit organizations in disadvantaged communities who have no idea they are participating in CRA-qualified events. Or maybe you have employees who want to participate in CRA-qualified events but don’t quite know what they are or how to find them. A CRA Training program will bring awareness to the needs of lower-income and disadvantaged communities and will show employees what that can look like. Many employees want to participate in the bank’s CRA program but just don’t know how.

Welcome Aboard sign

Start with New Hire Orientation 

Start with a simple CRA training at your bank’s new hire orientation. New bankers can learn a lot about the bank’s culture, values, and priorities by learning about the CRA program and where the bank focuses its activities.

Share these basics:

  • Why the Community Reinvestment Act exists 
  • Why the CRA is good for the community and the bank
  • What qualifies under the CRA based on the size of your institution (lending service and investment, community development test, etc.)

Add CRA to Annual Compliance Training Requirements 

For the rest of the bank, it’s important to periodically train and retrain employees on the CRA. Cover the basics of the CRA and then have focused training segments on specific community development activities. Share facts about your low- and moderate-income or disadvantaged communities, like where they are, who they are, and what challenges they face. This helps bankers understand that CRA is about more than compliance; it’s about improving our communities through various programs and services and changing lives through the power of economic development.

Business Unit Specific CRA Training

Consider specific training for business units. For example, you may want to focus on identifying community development lending with your commercial real estate division or focus on the impact of small business loans with your corporate banking group. Give your bankers the tools they need to identify CRA-qualified activities as they go about their everyday tasks. Help them understand that the CRA program is part of their business and can be rewarding, as well as profitable.

Don’t forget Executive Management. To achieve the kind of systemic change you need for the culture of compliance to take root, you’ll need your leaders to get on board! Executive Management is uniquely positioned to approve or deny larger, more complex, and more impactful CRA activities. They will be more likely to support a partnership with a CDFI that includes a large equity equivalent investment if they understand and embrace their importance to the community.

CRA Training doesn’t have to be a “one and done” either. Annual CRA training that reinforces its importance to the bank and the community will benefit your bank. Make sure to include your top service, lending, and investment activities for the year to drive home the impact for your bankers! 


 

P.S. Did you see I have a free course for bankers who are new to CRA? Click the button below or share this article with a colleague that might have inherited their bank’s CRA program and are not sure where to start!

2021 CRA Fundamentals Free Course