1 – Review all complaints relating to the institution’s CRA performance received by the institution (these should all be contained in the institution’s public file) and those that were received by its supervisory agency.
2 – If there were any complaints, evaluate the institution’s record of taking action, if warranted, in response to written complaints about its CRA performance.
3 – If there were any complaints, discuss the preliminary findings in this section with management.
4 – If there were any complaints, summarize in work papers conclusions regarding the institution’s record of taking action, if warranted, in response to written complaints about its CRA performance. Include the total number of complaints and resolutions with examples that illustrate the nature, responsiveness to, and resolution of, the complaints.
5 – Discuss the preliminary findings in the lending test section with management.
SOURCE: Intermediate Small Institution CRA Examination Procedures | OCC, FRB, FDIC, and OTS | July 2007