CRA
All CRA services are provided in conformance with CRA Examination Procedures appropriate for the size of your bank. (Small bank, Intermediate Small Bank, or Large Bank).
Performance Evaluations/Self-evaluations
This is our most extensive CRA service. We conduct performance evaluations that mimic CRA examinations aligned with your federal regulatory agency and your “asset size” under CRA:
- Small Bank
- Lending Test
- Intermediate Small Bank
- Lending Test
- Community Development Test
- Large Bank
- Lending Test
- Investment Test
- Service Test
We use your bank’s lending patterns, aggregate data, U.S. Census Bureau demographics, and impactful performance context to determine institution, stated, and assessment area ratings and performance conclusions. We also conduct thorough analyses to determining your CRA peer institutions.
Assessment Area Analyses and Demographics
Proper assessment area delineation is critical in avoiding regulatory concerns regarding:
- CRA, and
- The overlap with Redlining under Fair Lending laws and regulations.
Let us conduct your annual assessment area analysis in advance of regulatory requirements to update your CRA Public File.
We provide updated and historical demographics information provided by the U.S. Census Bureau.
Community Development
Community development covers:
- Community Developement loans;
- Qualified investments, grants, and donations; and
- Community development services
We offer reviews of each type of community development activity, including assessments of the documentations to show conformance with the CRA regulations. We also provide the determination of your CRA peer institutions and their community development performance relative to yours.
CRA Action Plans
If your CRA performance is in need of improvement, our CRA Action Plans develop targeted and reasonable recommendations to improve performance at the institution, state, assessment area, and lending product levels. Consider this service in advance of when your bank enters a new state by way of branching or merger/acquisition activity.
Consulting
We offer fixed fee or hourly billing to support CRA risk management principles to enhance your CRA Compliance Management System.