How to Build a Successful CRA Strategy and Action Plan for 2024 (While Keeping Regulatory Change in Mind)

CRA regulatory change is on everyone’s mind. How will it affect your CRA program? What data will you need to track? Who’s responsible for managing each part of the CRA exam? 

We may not have all the answers yet, but we do have some ideas on how to prepare your program for regulatory change and how to build a CRA strategy and action plan for 2024 that will keep your program compliant and ready for change. 

Each new year comes with exciting possibilities and is a great time to reflect on your CRA program. Now is the time to look back at what your program has accomplished in the past year and look forward to what impact you can forge this new year. Creating an annual CRA strategy is an industry best practice and lets you manage your strategic priorities along with the resources available for the year ahead. 

Here’s how to build your 2024 CRA strategy and action plan while keeping regulatory change in mind. 

Study the new CRA rule

Those 1,500 pages may be scary, but now is the time to study them and seek training. The more you know about the upcoming change, the better off you and your program will be when 2026 rolls around.

The CRA Hub is a great resource to learn about the new CRA regulations.

As you build your CRA strategy for 2024, keep the new CRA rule in mind and begin preparing what you can. You still need to get through the next two years and will probably go through another exam before the new rule takes effect. 

Align your CRA strategy with the bank’s corporate strategy

As a member of the CRA team, you’re responsible for leading programs and building support in the community that helps your bank connect with potential customers. As such, key stakeholders and the executive management team should see you as a key player in carrying out the bank strategy. 

Before you can build your own CRA plan or strategy, it’s important to consider the bank’s corporate strategy and priorities. Once you understand the bank’s key initiatives, you can align your CRA program’s priorities with corporate’s to impact the entire institution and the community. 

To learn about your bank’s key initiatives and corporate strategy, meet with the appropriate people and discuss. Ask how your CRA program could support the bank, and make sure to tell them how they might help your CRA program, as well as how your program may be affected by upcoming change. 

Consider all elements of your CRA program

When planning and outlining your CRA strategy for 2024, you need to keep all elements of your program in mind. Here are some things to consider:

• Collaborate with different business units to ensure you’re meeting the credit needs of the community. 

• Engage key internal bank stakeholders to maximize the bank’s community development services, loans, and investments.

• Create a system to ensure technical compliance with all required deadlines and activities associated with the public file, public notices, sunshine provision reporting, etc. 

• Acknowledge where you are in the CRA exam cycle. Your priorities will shift depending on whether you’re in year one of your exam cycle or if your exam is coming next quarter.

• Develop a plan to train key internal stakeholders such as commercial loan officers, retail staff members, and CRA team members embedded in different departments.

• Understand how upcoming CRA change will affect your program and what you should do now to prepare for this change.

• Take a look at your data tracking systems and determine if your process will cut it going forward. If you manually track CRA data on spreadsheets or outdated software, take a look at Kadince. Kadince software makes it easy to track and manage your CRA data all in one place. Schedule a demo to learn more.

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A key element of your CRA program is understanding that CRA is not always about creating new opportunities, but is about finding the opportunities that already exist. To do this, you should aim to give each team at least three CRA trainings a year. This will keep team members up-to-date on the new regulations and will help keep your program top of mind. Team members are more likely to forget about CRA when they haven’t heard from you in a long time. But if you train team members to watch out for CRA opportunities, you’re almost guaranteed to come across new services, loans, and investments that are eligible for CRA credit. 

Don’t make a plan before setting goals with your bank’s business units 

If you regularly meet with your bank’s business units, great! Keep up the good work. If you aren’t meeting with business units, you need to prioritize this in the new year. Your relationship with these key departments is critical as they influence your CRA performance and the time you spend serving the community. 

At the beginning of the year, you should reach out to each business unit (especially commercial lending, retail, and investment/treasure divisions) and set a time to meet. During this meeting, ask about their specific goals, priorities, and initiatives for the new year. Now when you make your CRA action plan and set your own goals, you can ensure they align with the rest of the bank’s goals and help each business unit thrive.

And when each business unit thrives, so does your CRA program. But keeping these units involved in CRA is easier said than done. A couple ways to keep these units involved include setting shared goals, giving CRA training, sharing how they’ve helped your program in the past, and routinely reporting on their performance. 

Perform a self-assessment 

Two key aspects of running a successful CRA program include performing self-assessments and creating a CRA plan. Your self-assessment helps you look backwards at what you’ve accomplished and where your strengths and gaps are, while your CRA plan looks forward at how your program should meet your goals. Both of these allow you to advocate for your program and get the support you need. 

Performing a CRA self-assessment doesn’t have to be difficult. If you don’t have the time or resources to perform a full assessment, simply make a list of how your bank has served its assessment areas. List the highlights of your program and add current initiatives to elevate your CRA program performance. Identify some performance gaps and your plans to fix these gaps. This will serve as a high-level overview for examiners and shows intent as you continue to build your CRA program.

Build your CRA plan

You aren’t required under the Community Reinvestment Act to build a plan, but it’s an industry best practice and will help take your CRA program to the next level. Keep your plan simple, and don’t worry about making it perfect. Your plan can be one page or it can be 20; everything is up to you. 

As a general rule, you should start your plan with an overview of your CRA program. Where are you in the exam cycle? Who’s your regulator? What are some of the past year’s accomplishments? How are you preparing for CRA change?

Next, list out your bank’s strategic priorities, both long- and short-term. Include your CRA performance goals, and make sure to mention goals for your lending, services, and investment tests, as well as goals for fee and investment income, deposits, and various business units. 

Some sections you might include are how you’re going to conduct CRA training, any applicable regulatory changes, technical compliance, public relations, and marketing. 

At the very least, your plan needs to answer these questions:

• What are 2–3 areas of the bank you want to learn more about this year?

• How can your program support various business units?

• Which areas of the bank need more CRA training this year? 

For a more complete list of questions to ask yourself when building your CRA plan, download the free PDF. This will help you think about your CRA program and build the perfect plan to promote your program and make a difference in your community. 

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Most of all, remember that your CRA journey is your CRA journey. Don’t make it more complicated than it needs to be, and have fun with it. 

Once you’ve created your CRA plan, you can share it with executive management, internal business units, the compliance department, and even CRA examiners. This will help keep everyone in your bank on the same page and set expectations throughout the company.

Next Steps

It’s time to build your 2024 CRA strategy and action plan! Here are your next steps:

1. Study the new CRA regulations and determine how you are going to prepare your program for the change

2. Download the free PDF below for a list of questions to ask yourself when building your CRA plan

3. Get a copy of your bank’s strategic plans for 2024, if available

4. Meet with executive management to learn about their vision for the bank, and ask them to tell you their priorities

5. Meet with business units to learn about their goals and how your program can support them

6. Identify 2–3 strategies that support the bank’s/business unit’s strategic plans while supporting your CRA program

7. Compile all the details into one document 

8. Set target dates and implement

Good luck! 

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*This article was peer-reviewed by Linda Ezuka, owner of CRA Today and official partner of Kadince. 

(This article is an updated version of our “How to Build a Successful CRA Strategy and Action Plan for 2022” article and reflects the upcoming CRA regulatory changes.)

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.