By Linda Ezuka | September 16, 2021 | 3 Minute Read

Essential Steps Every CRA Officer Must Follow to Ensure a Smooth CRA Exam

Running a CRA program is difficult during the best of times. And when it’s time for a CRA exam, your job only gets more stressful. 

But when you have a clear picture of what’s expected of you, your exam can be a lot easier. 

In last week’s blog post, we outlined the milestones an examiner goes through during an exam. Now that you have a solid handle on how an examiner approaches a CRA exam, it's your turn to anticipate their approach and ensure a smooth review of your CRA program and bank performance.

Here are the steps you should take during a CRA exam cycle, beginning when your bank receives the notification of an upcoming exam: 

Announce upcoming exam to stakeholders


It’s imperative that your bank considers a regulatory exam as mission-critical and indicates that "all hands are on deck." As a CRA Officer, it’s your job to inform and engage all stakeholders in the preparation and site details associated with running a smooth CRA exam.

Inform loan operations


After reaching out to executive management, the loan operations team is next up on your priority list. The loan operations division plays a key role in supporting the CRA data integrity review, so start early to avoid disrupting key loan origination processes.
They have an important job in uploading loan data and documentation for the data integrity review portion of the CRA exam. And it goes without saying, keep these valuable team members happy!

 

Prepare for an onsite examination


Making sure your examiners are well cared for is an often overlooked aspect of onsite CRA exams. Someday in the not too distant future, examiners will be back onsite. Reserve private conference rooms, parking, building access, and even local menus to support their lunch breaks! 

Position and defend your CRA performance


No one knows your bank or your community better. When conducting a CRA self-assessment, make sure to position your bank as having maximum impact. A CRA self-assessment is the number one strategy you can control to prove you’re meeting the credit needs of your community and have a rating presumption in mind backed up with concrete evidence. The more time you put into the self-assessment, the better prepared you’ll be for a solid exam outcome. 

Never leave your bank's performance entirely up to an examiner to uncover or figure out; it is too much of a burden given time and capacity limitations. Know your performance gaps and work with your key stakeholders to further support your efforts to serve and address key gaps for internal and external performance context. Your self-assessment is where you tell your CRA story and assert your presumptive rating. If you invest in this step and properly assess your bank’s overall performance, you should have a good idea of your expected rating. 

Actively manage the onsite exam 


Once you wrap up the exam and get your rating: celebrate with your key stakeholders, rest, plan, and repeat! Oh, and you need to develop a strategic path forward based on your exam outcome! 

Good luck!

While every exam will likely be stressful, yours can be much less stressful with Kadince. Kadince makes it easy to track, manage, and report your CRA data. Instead of digging through old files and creating several spreadsheets, you’ll already be prepared when that exam notification lands in your inbox. Schedule a personalized demo to learn more!


None of Kadince, Inc., its affiliates, or its respective employees, directors, officers, and agents (collectively, “Kadince”) are responsible or liable for any content or information incorporated herein. Read full disclosure.

Linda Ezuka | Owner, CRA Today

With over 27 years of community development experience, with an emphasis in CRA, compliance, training, community development lending, and CDFI initiatives, Linda works with financial institutions to provide comprehensive CRA training, up-to-date resources, and proven strategies to remain compliant. She helps CRA professionals master the art of the CRA and transform communities through the power of economic development. To learn more about Linda & CRA Today, visit her website.


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