Your CRA Exam is Over. Now What?

Woman doesn't know what to do after her CRA exam

Your CRA exam is finally over. (Longest 2–3 months of your life, right?)

First of all, take a deep breath. Pat yourself on the back. The last several months have been a stressful blur of paperwork, examiners, and “why didn’t this count?”s. But you survived!

Because so much of your time has been taken up by this CRA exam, it can be difficult to know what to do next. But don’t worry, because we’ve got your back. Here’s what to do after your CRA exam is over.

Take a much-needed break

With your CRA exam behind you, there’s finally a moment of peace. If you’d like, now is a great time to take a vacation or some much-needed PTO. (Relaxing on the beach sounds like a great idea.)

Once you’re back, it’s time to examine your results and start preparing for your next exam. It probably feels like you’re either preparing for an exam or recovering from one. But that’s just the reality for hardworking CRA Officers like you.

Examine your results

Whether you achieved a Satisfactory, Needs to Improve, or Outstanding rating, there’s always something you can work on for the next time around. It’s important to reflect on your CRA program’s performance and build a plan for the future. This will help your CRA program grow and position the bank to do even better on your next exam.

If you have any questions about your rating or why you didn’t get credit for that impactful community initiative (chances are you’ve been here), you should reach out to your examiner and ask about it (although ideally you’d have asked during the exam). Examiners aren’t necessarily aiming to sabotage your CRA performance, but the subjectivity of the regulation makes this process challenging. Any good examiner will be happy to explain their reasoning behind your score and address any concerns you may have. And having a good relationship with your examiner is a critical part of building a lasting CRA program.

Identify gaps and share with your team

After reviewing your exam performance and speaking with your examiner, you should have a good idea of where your program fell short and where it shined. Identifying the gaps in your program and working with your team to fix them will set you up for success and boost your CRA program.

A good place to start is by looking at any warnings you may have received. You may have gotten lucky this time, but next time you probably won’t. So take this opportunity to reflect on where you went wrong and what you can do to fix it.

Luckily, you don’t have to do this alone. Even if you’re part of a small CRA team (teams of just 1, raise your hand), there are others in your institution who care about your program and can help you identify gaps and strategize for the future.

If your institution has a CRA committee, this is the perfect time to call on them for help. Make sure to debrief them on your exam results and explain what gaps you’ve identified so far, and then ask for their opinions and ideas. You aren’t alone in this work, so don’t leave everything up to yourself.

Build your CRA action plan

Now it’s time to build your CRA strategy and action plan. This is a vital document that will help you cast a vision for the next exam period and put into practice the ideas you and your team have come up with.

Your CRA action plan doesn’t have to be long (it could be 1 page or it could be 20) or difficult. In fact, simple, concise plans are often best.

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?

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.

Talk to executive management

Once you’ve had a chance to examine your results and build a plan for the future, it’s time to talk to your executive team.

Hopefully your bank leadership team knows a bit about CRA and how important it is to the bank. If not, take a few minutes to share what they need to know about CRA.

Before presenting your plan to the leadership team, make sure you’re able to clearly describe what you want and how you plan to make your CRA program even better. This means you should practice your pitch! You don’t want to stand in front of all those people and forget everything you ever thought you knew (what does CRA stand for again?).

This is your chance to build support for new CRA initiatives and ensure that you get the resources you need to do well on your next exam. That may mean asking for more team members, funds, or software (Kadince, anyone?). You want to make sure to nail this presentation. If the leadership team has your back, other departments are more likely to support you and your work.

Get to work!

Whew, that was a lot of work. You’ve taken a break, examined your results, identified gaps in your program, built a CRA action plan, and spoken to executive management. Now it’s time to start preparing for your next CRA exam.

I know, I know. No rest for the weary. But CRA is an ongoing process that can’t be ignored. So now that you know where you want your program to go, it’s time to take it there.

So dust off that self-assessment, revisit your action plan, and get out in the community.

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To learn about the recent CRA rule change and what you should do now, check out this article.

*This article has been peer-reviewed by Linda Ezuka, CRA expert and owner of CRA Today. Want more CRA exam prep tips? Check out Linda’s new book: Outstanding: A practitioner's guide to CRA exam readiness.

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.