CRA

This is our most extensive CRA service.  We conduct performance evaluations aligned with your federal regulatory agency and your “asset size” under CRA.  As appropriate, we evaluate performance within the Lending, Community Development, Investment, and Service Tests.  We use your bank’s lending patterns, aggregate data, demographics, and impactful performance context to determine institution and assessment area ratings and performance conclusions.

Proper assessment area delineation is critical in avoiding regulatory concerns regarding CRA and the overlap with redlining under Fair Lending laws and regulations.  We evaluate assessment areas for CRA and Fair Lending, noting where Reasonably Expected Market Areas (REMAs) are appropriate, per the Interagency Fair Lending Examination Procedures (IFLEP). Let us conduct your annual assessment area analysis in advance of regulatory requirements to update your CRA Public File.

Community development covers loans, investments (including grants and donations), and services.  We offer reviews of each type of community development activity, including assessments of the documentation to show conformance with the CRA regulations.  We also provide the determination of your CRA peer institutions and their community development performance relative to yours.