2014 NICRC: Five Important Lessons Learned

Looking over notes from the 2014 National Interagency Community Reinvestment Conference, certain themes recurred throughout the sessions.   The following is our list of the five most important insights for bankers.

  1. Are the right people involved in your CRA program?

As the CRA Officer, do you have the appropriate level of authority and prominence in your bank to effect product development, investment and lending decisions?   One consideration would be to report directly to the CEO or President of the Bank, ensuring that CRA is supported by the highest level of management and allowing you easy access to the Board of Directors.  It would be difficult to argue that CRA isn’t a priority when Senior Management is actively involved in community development decision-making at your organization.

  1. Remember that just because you’re the CRA Officer, you don’t have to do it all.

Depending on the size and complexity of your institution, it may be difficult for you to manage all aspects of CRA in every assessment area.  Look for ways to involve other employees to assist in CRA monitoring and tracking.  One suggestion offered was to appoint a market liaison for each of your assessment areas to act as your CRA leader in their community.   Also, consider implementing online tracking tools such as SharePoint or other shared databases where your employees can directly input their financial literacy, volunteer participation or other qualifying CRA activities.

  1. Be tight on outcomes but loose on process.

As a CRA Officer, combat the need to establish rigid processes and procedures to solicit non-profit and other charity participation.   The last thing you want to do is miss a great CRA opportunity because someone forgot to list their mission statement in the right box on your review form.  As highlighted in the “Cross-Sector Collaboration” session, CRA Officers can benefit by using innovate approaches in community development.  Remember, the goal is to facilitate community reinvestment and although it may be difficult at first, a looser approach in achieving that goal may benefit your CRA program in the long run.

  1. Document your CRA story.

It’s up to you to tell the story of your CRA performance to your examiners – make sure it’s accurate and clear.   Documentation is key…keep it organized by year, sufficiently detailed, and readily available.  Remember, more and more examination work is done offsite, so think about how you demonstrate CRA qualifying activities to an examiner that may never come to your office and could possibly have never stepped foot in your state.

  1. Don’t forget, use your CRA partners as a resource.

The best person to explain the details of a non-profit’s operations is someone at the non-profit.Don’t hesitate to discuss your tracking requirements with your community partners and elicit their own thoughts and explanations of how they serve the community in which you both work.Getting details about the services and economic development from your partners will not only ensure that you fully understand the scope of your partnership but could highlight areas for future opportunities.

Check back for our next post for some important insights for community partners and non-profits.