How to Build a Good Relationship With Your CRA Examiner

CRA Officers are often told to build relationships throughout their financial institution. These relationships will help your CRA program grow, provide fresh volunteers, help you mine for community development loans, and overall help to create a culture of compliance throughout your institution.

But an important relationship that CRA Officers often overlook is the one with your CRA examiner. 

Your CRA examiner may not be around as much as your coworkers, but the relationship you have with your examiner may impact your CRA exam rating. You’ll want to communicate well, be confident in your data analytics, and get your point across when discussing your bank’s CRA performance. That’s why it’s crucial to build a good relationship with your examiner. 

Building a good relationship with anyone is easier said than done, and building a relationship with your examiner is even more difficult when it only takes place over a few weeks every two or three years. But not to worry, because it can be done! Here are a few ideas that might help you build a professional relationship with your examiner. 

Start early

Once you receive your CRA entry letter (a.k.a. Compliance Information and Document Request (CIDR)), it’s a good idea to reach out to your examiner. Even just sending a quick email saying that you’re excited to work with them and are in the process of getting everything ready will help your relationship start off strong. Communicating with them early will show your examiner that you take the CRA seriously and want to do everything in your power to have a quick, painless CRA exam. Your examiner knows how beneficial your work is to your community, and showing them that you truly care and want what’s best can help get your exam started right. 

And if you don’t yet know exactly who your examiner will be, that’s okay! Send an email to the Examiner In Charge (EIC) if you can. And if that doesn’t work, simply reach out to your examiner as soon as they are “on-site.” 

Another way to start early and set yourself up for success is by making sure you have everything you need ready for when the exam arrives. This may mean appointing an internal CRA liaison to communicate with you and your examiner (if part of small CRA program, this may just be you). Either you or this CRA liaison will prepare all documents and make any necessary arrangements. If your exam is on-site, here are some things you should prepare:

• Building access

• Reserved parking space

• List of nearby restaurants and menus

• Key contact list

You want to make everything as easy as possible for your examiner. According to CRA expert Linda Ezuka in her book Outstanding, “It’s important to remember that your lead CRA examiner is balancing many competing priorities for conducting the CRA exam.” They don’t have time to worry about the logistics like where they’re supposed to park. Help them out!

Make your data easy to find and navigate

The easier you can make an examiner’s job, the better. Your examiner probably doesn’t want to sift through hundreds of spreadsheets of data or wonder whether they have everything they need. By making your data easy to find and navigate, you can take away a lot of the stress that comes with being an examiner. 

Having easily accessible data starts with your tracking method. If your institution still uses various systems like spreadsheets and binders to track community development loans, services, and investments, then you’re in for a tough time. The best way to track your data so it is easily accessible for examiners and your team is by tracking everything in Kadince. 

Kadince keeps all of your CRA data in one place so you aren’t scrambling back and forth between spreadsheets or folders wondering where Bob put that supporting documentation. Then when your exam comes around, it’s easy to build the report your examiners are requesting. You can even give your examiners access to your Kadince data, so they can see all the data they need to determine your rating. Talk about making your data easy to find, right?

To learn more about using Kadince during your CRA exam, schedule a demo.

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Set proper expectations and be transparent

In addition to making sure you have all the necessary documentation and information ready before your exam, you should do your best to set proper expectations about your program, your bank, and your process.

Be transparent with your CRA examiner about your institution's CRA performance, challenges, and goals. There’s no reason to hide anything from them. Chances are they’ll figure it out soon, anyway. Being upfront about the challenges you’ve faced and what you’ve done to prevent them will show your examiner that you’re willing to address any issues and improve your institution's CRA performance. Building a strong relationship is all about trust, and being transparent about your program is a great way to build that trust.

The best way to set expectations and communicate the nuances of your program is with a self-assessment. CRA self-assessments are a great way to not only spell out your program for examiners, but also to take a deeper look at yourself and identify areas where you can improve. Linda Ezuka says, “Completing a self-assessment is, by far, the most important task leading you on a path to ‘Outstanding.’” That’s a pretty big deal!

You should conduct a self-assessment as early as possible, ideally long before your exam begins. You can even reach out to your examiner with questions specific to your institution. This will show that you are proactive and want to do the best you can. 

Respond to questions quickly and accurately

Your examiner is bound to have questions. And the quicker you respond (accurately) to these questions, the more confidence your examiner will have in you. Whether your examiner is asking for more detail about a CD loan, needs further information about an assessment area, looking for a document related to an investment, or just has a general question, it’s your job to find the answer and report back. A good rule of thumb is to respond to any question within 24 hours, even if that response is simply to say that you’ll need more time to find the answer.

Questions are a natural part of the CRA exam process. You know your community best, after all, while your examiner may just be getting acquainted with your institution and assessment areas. Some questions are a good thing! But if you follow the rule of making your CRA data easy to find and navigate, chances are you’ll get much fewer questions. The fewer questions an examiner has, the quicker they can get through your exam, and, likely, the happier they’ll be. And as Linda says, “a happy examiner is a fair one.”

Seek to understand their perspective

You’ve spent years building your CRA program, and many of the loans, services, and investments you’ve initiated are close to your heart. Sometimes it can feel like an examiner is attacking all your hard work by not considering it under the CRA. But this almost certainly isn’t true. And the fact of the matter is that during this exam follow-up, you may hear some things you don’t like. 

Disagreement is normal, but that doesn’t mean you should take it personally or as a sign that the examiner hates your program. This is your chance to learn and improve your CRA program in the future (and chase that Outstanding rating). You might be grateful to your examiner for pointing out your flaws and giving you some actionable advice.

End on the right note

Before the end of your exam, you should always request an exit meeting (or a pre-exit meeting if you have other topics to discuss). During this meeting, you should ask your examiner to explain their findings and help you understand what they will say about your program. 

Make sure to request a list of the community development activities they qualified and a list of what they didn’t. While they may not offer this without prompting, you are certainly allowed to request it. This step is critical! You don’t want to be blindsided when the final results come out, and this is your chance to get ahead of any potential negative feedback. 

This follow-up will be crucial to understanding your exam and preparing your CRA program for the next one. Don’t put this step off! This will show examiners that you care about your institution's program and want to do better in the future. And that’s bound to earn you some points in the examiner’s book and strengthen your budding relationship. 

And once your exam is officially over, you might send a letter or email thanking the examiner for the time they spent with your institution. Some gratitude is always appreciated!

Utilize feedback during future exams

Your CRA exam may have just finished, but now it’s time to prepare for your next exam. And the feedback you’ve received from your examiner during the exam can be very helpful. 

You may be so involved with your CRA program that it’s difficult to see its blind spots. Your examiner is the perfect person to catch these, point them out, and steer you in the right direction. Take all examiner feedback into consideration when building your CRA strategy and action plan. Chances are your program will be much better for it. 

And when your next exam comes, your new examiner may see this feedback being put to good use. This will strengthen your relationship since they know that you take what they say seriously. And then the process can start all over again.

As you can see, building a good relationship with your CRA examiner is a critical step to managing a thriving CRA program. Your examiner has a lot of industry knowledge and can pull from other good programs they’ve seen. You’re bound to benefit from this relationship and gain the tools you need to strengthen your own CRA program. Don’t put this relationship on the back burner. Rather, actively try to be a reliable contact and provide your examiner with a good experience. Your examiner, and your program, will thank you for it. 

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*This article has been peer-reviewed by Linda Ezuka, CRA expert and owner of CRA Today. 

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.