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.
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:
- 20 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): 7
Continuing Professional Education Unit (CPE): 83.6
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 one small bank.
- Reviewed an ISB Community Development Test and related workpapers with a coach and determined how community development activities were qualified or not qualified.
Pre-Course Assignment
The items below constitute the pre-course assignment. The pre-course assignment is due the Thursday prior to the first day 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:
- Complete the omitted information in the Description of Institution and Assessment Area portions of the case study bank's CRA performance evaluation.
- Identify five observations of performance context issues that might impact the case study bank's CRA performance.
- Develop five questions for the community contact interview for the case study.
- Develop five CRA-related questions for the entrance meeting with the case study bank.
- Read the compliance Examination Manual, XI. Community Reinvestment Act, Sections 1.1 Community Reinvestment Act, 2.1 Small Bank, 3.1 Intermediate Small Bank, 4.1 Large Bank, 7.1 CRA Ratings System, 9.1 Community Contacts, 10.1 Full Scope and Limited Scope CRA Assessment Areas, 11.1 Sampling Guidelines CRA, and 12.1 Interagency Questions and Answers Regarding Community Reinvestment.
- Read the Intermediate Small Bank Single-Rated Area writing guide.
- Answer 15 knowledge check questions on the reading assignments.
NOTE: The Division of Depositor and Consumer Protection (DCP) has authorized 20 hours of official time to complete the pre-course assignment.
Post Course Recommendation and Feedback
Participants should be scheduled to conduct a small bank or ISB 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
- Assessment Area Definition: Identify the technical requirements for delineating assessment areas under the CRA and apply the requirements of the Interstate Banking and Branching Efficiency Act (IBBEA).
- Performance Context: Define performance context, its components, and the sources of performance context data, analyze performance context factors, and present the data in a performance evaluation.
- Community Contacts: Identify the purpose of community contacts, describe the CRA examination requirements for conducting a community contact, complete a community contact form, and apply the community contact results to the CRA performance evaluation.
- CRA Examination Scoping: Select appropriate loan products and samples for the ISB lending test. Determine the scope and describe the loan data analyzed.
- Small Bank Lending Test: Define and analyze the components of the small bank lending test, which includes Loan to Deposit (LTD) Ratio, Assessment Area Concentration, Borrower Profile, Geographic Distribution, and Consumer Complaints.
- Community Development (CD) Activities: Determine and evaluate CD lending, investments, and services and recognize how CD activities apply to other types of CRA examinations.
- CRA Performance Evaluation Ratings: Weigh the lending and CD tests in arriving at a preliminary composite rating; assess ratings consistent with the requirements of IBBEA; and adjust rating conclusions based on the effect of discrimination or other illegal credit practices.
- Meetings with Bank Management: Conduct effective discussions with bank management and apply information gathered from management to the CRA performance evaluation. Conduct effective exit meetings with management to communicate the CRA examination findings with respect to FDIC policy and guidance as outlined in the Compliance Examinations Manual.
More Information
For 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
The 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 Pamela Sweeney or Helen Briggs.