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Regulations and Examinations

Compliance Training Program - Community Reinvestment Act (CRA)

Last Updated: February 3, 2023

Program Overview

Community Reinvestment Act (CRA) School addresses the CRA regulation with emphasis on the small and intermediate small bank (ISB) CRA examination procedures.  The course consists of lessons, group exercises, and a case study that takes the students through an ISB CRA examination step by step, including the creation and presentation of a CRA public evaluation.  Participants actively take part in group case studies and other classroom activities.  The pre-course learning activities are critical to the completion of the course and must be submitted prior to attendance.

Skills Taught

By the end of this course, students will have been taught how to:

  • Define an ISB and describe relevant performance criteria.
  • Evaluate assessment area (AA) appropriateness.
  • Develop a performance context for a bank.
  • Conduct a community contact.
  • Conduct ongoing discussions with management.
  • Develop the scope of the CRA examination.
  • Analyze lending activity under the ISB performance criteria.
  • Apply the basic concepts of community development lending, investments, and services.
  • Determine and support an ISB’s CRA rating.
  • Prepare an ISB CRA performance evaluation.
  • Discuss CRA evaluation results with management.
  • Recognize large bank examination concepts.

Duration and Format

This course contains:

  • 16 hours of Pre-course work (Independent Self Study)
  • 2 weeks of Facilitated classroom discussion/lectures
    • Small group activities
    • In-class project

Level and Credits

Basic
Continuing Education Unit (CEU): 6.8
Continuing Professional Education Unit (CPE): 81.5

Target Audience

FDIC participants should attend in accordance with the parameters outlined in the Examiner Training and Development Policy.  State Banking Authority participants should have a minimum of 23 to 27 months of experience in compliance examinations after entering the compliance discipline.  There should be a minimum of six months after attending Scoping and Planning for Examinations School.  This course is open to appropriate staff of the FDIC and partner government regulatory agencies.  This course is not open to the public or staff of private banks.

Prerequisites and Prior Work Experience

Prior to attending, the Community Reinvestment Act School participants must have satisfactorily completed:

  • Review OJT Lesson Plan for Conducting Community Contacts.
  • Review OJT Lesson Plan for Small Bank Community Reinvestment Act (CRA).
  • Written a CRA performance evaluation for at least two small banks.
  • Review of community development (CD) activities is beneficial, but not required.

Pre-Course Assignment

The items below constitute the pre-course assignment. The pre-course assignment is due in general two weeks/11 business days prior to the start of the session. The exact date the work is due for any given session will be specified in the pre-course information sent approximately two months prior to the start date. Prior to attending the course, participants are required to complete the following pre-course assignments:

  • FDIC Participants:  Review the OJT lesson plan for Conducting Community Contacts and Small Bank CRA.
  • All participants:  Write a CRA Performance Evaluation for at least two small banks.
  • Review an ISB Community Development Test and related workpapers with your coach and determine how the community development activities were qualified or not qualified.  *This pre-requisite can be met by reviewing CD activities onsite at a bank.

NOTE: The Division of Depositor and Consumer Protection (DCP) has authorized 16 hours of time to complete the pre-course requirements.

Post Course Recommendation and Feedback

Participants should be scheduled to conduct a CRA examination as soon as possible, but no later than six months after completing this course, to reinforce the skills learned from this session.

A Summary Evaluation Form, which provides a comprehensive analysis of the participant's in-class and project exercises, is sent to the participant's Field Supervisor approximately thirty days after the conclusion of the school.

Key Topics Covered

  • Evaluate assessment area (AA) appropriateness
    • Participants will identify potential concerns in scenarios involving several delineated AAs.
  • Develop a performance context for a bank
    • Participants will identify the sources of performance context information and instances where performance context has had an impact on CRA findings.  Participants will review scenarios and determine whether performance context data serves as a mitigating factor for poor performance.
  • Conduct a community contact
    • Participants will choose the best contact for the CRA examination and conduct a community contact interview.
  • Conduct ongoing discussions with management
    • Participants will identify topics and questions to be explored through ongoing management discussions.
  • Develop the scope of the CRA examination
    • Participants will review case study information and write a scope comment.
  • Analyze lending activity under the ISB performance criteria
    • Participants will assess the case study bank’s lending test performance for Loan to Deposit (LTD), AA Concentration, Borrower Profile, Geographic Distribution, and Consumer Complaints.
  • Apply the basic concepts of community development lending, investments, and services
    • Participants will review the CD loan, investment, and service lists provided by the bank’s compliance officer to determine what is qualified and evaluate should receive the greatest weight. 
  • Determine and support an intermediate small bank’s (ISB) CRA rating
    • Participants will determine how the ratings would be impacted by the factors discussed and rate the Lending Test, Community Development Test and Overall Institution Rating.
  • Prepare an ISB CRA performance evaluation
    • Participants will review the Bank of Anytown criteria and write all performance criterion for the intrastate case study bank with two AAs.
  • Discuss CRA evaluation results with management
    • Participants will identify the most common elements of an effective agenda for an ISB exit meeting and conduct an exit meeting with bank management.
  • Recognize large bank examination concepts
    • Participants review a large bank PE, rate the institution, and note strengths and weaknesses.

More Information

CPE Credit logoFor information regarding administrative policies such as complaints and refunds, please contact Corporate University, Attn: NASBA Representative Ava Livas, Room A-3025, 3501 North Fairfax Drive, Arlington, VA 22226 (703) 562-2463.

The Federal Deposit Insurance Corporation is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: NASBARegistry.org

IACET logoThe Federal Deposit Insurance Corporation (FDIC) is accredited by the International Association for Continuing Education and Training (IACET) (www.iacet.org). The FDIC complies with the ANSI/IACET Standard, which is recognized internationally as a standard of excellence in instructional practices. As a result of this accreditation, the FDIC is accredited to issue the IACET CEU.

For more information concerning course content and administration, please contact Denise Roth or Janice Crawford.