CRA Volunteer Services

AVP at a bank ($986MUSA)
If you have a Bank employee that volunteers on the Board of local hospital, health care clinic, etc. how do you document LMI persons? Is there a difference of documentation required for Intermediate Bank vs Large Bank? Is there a difference between regulatory agencies?

    What is a Fair Lending Compliance Management System?

    Good afternoon, Bankers! Today we are discussing fair lending compliance management system (CMS) components and how fair lending programs can ensure compliance. This post was originally published on the Ncontracts blog.

    Preventing and detecting discrimination with an active fair lending (sometimes referred to as Safe and Responsible Lending) compliance management system  is essential for all financial institutions (FIs). FIs don’t just have a moral obligation to prevent and detect discrimination—they also have a legal obligation. Lending practices or programs that negatively impact a protected class can result in fines or enforcement actions—even if the discrimination was unintentional...

    READ THE FULL ARTICLE: Download the attached PDF

      CRA Reporting and PPP Loans

      VP at a bank ($1.5BUSA)
      We are a large bank this year so trying to figure out CRA reporting and am confused on the PPP loans.  One of the FAQs I read states that PPP loans are Small Business Administration (SBA) 7 (a) loans.  Banks should follow Call Report requirements for reporting PPP loans based on the loan type, amount and collateral, as applicable.

      If we did a PPP loan to a farmer, would that be coded as a SB loan type 1 or SF loan type 2?



        CRA Modernization

        AVP at a bank ($986MUSA)

        We are an intermediate Bank. Can we start implementing the increased loan amounts for our CRA lending test for Small Business/Farms? 

        Intermediate Banks are only required to delineate AAs, Data Collection and recordkeeping requirements for Deposit accounts. Correct? Have any of you geocoded your deposit accounts yet? If so, what was the software you used?  

          CRA Public File - Intermediate Small Bank

          VP at a bank ($519MUSA)
          As an intermediate small bank for CRA purposes, do we follow the "small bank" CRA public file requirements or are there additional requirements for the public file since we are an intermediate small bank?  Does intermediate small bank fall into the "small bank" category in this Act? I'm specifically wondering about the items listed within 228.43(b) Additional Information available to the public - (1) Banks other than small banks.  Thanks.

            Lending compliance in 2021: Top challenges we’re seeing from the front lines | Free webinar next week!

            Good afternoon, Bankers! I wanted to extend an invite to you all to next week's webinar from Ncontracts on how best to tackle lending compliance in 2021.

            Thursday, February 25, 2021 @ 2:00 PM CT
            Learn more and register here.

            From the COVID-19 pandemic to a new presidential administration, the lending compliance environment is always evolving. What are the greatest regulatory challenges facing lenders today? What do you need to do to remain compliant? Is your compliance management system up to the task?

            In this webinar, we’ll highlight the top challenges, complaints, and worries we’re hearing about from banks, credit unions, and mortgage companies like yours—and what to do about it.

            They include:
            • The evolution of data management, protection, and analytics
            • Fair lending
            • CRA modernization
            • Focus on governance framework
            • Operational resilience and third-party risk management
            • Cybersecurity, privacy, and financial crime
            • Aligning lending compliance with your compliance management system
            Don’t miss this chance to hear what your peers are reporting and find out how to prepare for the year ahead! Register here.