Description

* Please note that the recordings will not be immediately delivered to you. Upon purchasing please allow 24-48 hours for delivery. The recording will come in the form of a web link via e-mail from brent@mycomplianceresource.com. The training manual that corresponds with the recording will be automatically delivered upon purchasing via email from the website.

This is a bundle features two of our Community Reinvestment Act webinars Identifying and Documenting CRA Community Development Activities and CRA Review and Update at a discounted rate.  Each recording is available separately by clicking the titles below.

CRA Review and Update

WHAT?
CRA is not a game, but like playing a game once the rules are mastered results improve. This program explains the rules as they currently exist and explores the changes to the rules that are underway.

It has been years since the federal bank regulatory agencies have overhauled the Community Reinvestment Act regulations, but they are constantly tinkering with the rules.

During November 2017 the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board, and the Federal Deposit Insurance Corporation (the Agencies), published  a final rule to amend their respective Community Reinvestment Act (CRA) regulations. The rule amended the definitions of “home mortgage loan” and “consumer loan” and the public file content requirements to conform to revisions made by the Consumer Financial Protection Bureau to its Regulation C, which implements the Home Mortgage Disclosure Act. The Agencies also made technical amendments to remove unnecessary cross references as a result of the amended definitions, and to remove an obsolete reference to the Neighborhood Stabilization Program. The revisions were effective on January 1, 2018.

On September 5, 2018 the OCC published an advanced notice of proposed rulemaking (ANPR)  to modernize the CRA regulations. A new CRA regulatory framework would help regulated financial institutions more effectively serve the convenience and needs of their communities by encouraging more lending, investment, and activity where it is needed most; evaluating CRA activities more consistently; and providing greater clarity regarding CRA-qualifying activities. A transformed or modernized framework also would facilitate more timely evaluations of bank CRA performance, offer greater transparency regarding ratings, promote a consistent interpretation of the CRA, and encourage increased community and economic development in low- and moderate-income (LMI) areas. In addition, these types of revisions would align with the transformation of the banking industry and reduce the complexity, ambiguity, and burden associated with the regulations. The comment period on the ANPR closed on November 19, 2018. A Proposed Rule, issued jointly by all of the bank regulatory agencies, is expected in early 2020.

WHY?
Bankers should view the current CRA ratings as a game. You need to learn how to play the game well. The challenge of playing the game is made more difficult as the agencies continuously change the rules of the game. This recording contains core knowledge needed by all lenders to comply with the current rule and to understand the direction in which the CRA regulations are headed.  Also:

• The detailed manual is a great desktop reference; and
• The presenter has decades of experience with this topic.

TOPICS
This two-hour recording includes:

• A review of the basic requirements of CRA and its implementing regulations, including:
• Performance tests, standards, and ratings;
• Assigned ratings;
• Assessment area delineation;
• Public file requirements;
• CRA notices; and
• Community Development activities;
• An explanation of the annual adjustment to the asset-size thresholds used to define “small bank” and “intermediate small bank;” and
• An update on the status of the revisions of the CRA regulations.

WHO?
The recording is designed for management of the loan department, Compliance Officers, CRA Officers, marketing staff and auditors.

Identifying and Documenting CRA Community Development Activities

WHAT?

Every bank (small, intermediate small or large) needs to identify and document its community development (CD) activities in order to achieve the best possible CRA rating. Volume and distribution of loans are the primary factors that determine a bank’s overall CRA rating. A bank can achieve a great rating without any CD activities, but the likelihood of an outstanding or satisfactory rating increases with the volume of CD activities. While CD activities are not the primary factor in determining the overall rating many banks spend a disproportionate amount of time identifying and documenting CD activities.

The regulations and interpretations that define what qualifies as a CD activity are complex. In some cases an activity that appears to be an obvious example of a CD activity may not qualify as a result of a small exception in the rules. It is not uncommon for an activity that does qualify as a CD activity to go without credit due to failure to document the activity and bring it to the attention of the examiner.

WHY?

The failure to achieve a Satisfactory or Outstanding CRA rating can increase the difficulty in getting various applications approved by your federal regulator.  A lower rating results in additional work to restore the rating. This program provides the information needed to assure proper credit is given for CD activities thereby assuring a higher rating and limiting the additional burden of a lower rating. Also:

• The detailed manual is a great desktop reference; and
• The presenter has decades of experience with this topic.

TOPICS

Upon viewing of this two-hour recording you’ll understand:

• Recent revisions to the definition of “community development” including why the reference to the Neighborhood Stabilization Program was eliminated and the impact of that action;.
• The importance of CD activities for small, intermediate small and large banks;
• Which loans receive CD credit;
• Which qualified investments receive CD credit;
• Which services receive CD credit;
• The consideration given to CD activities that occur within and outside of your assessment area;
• The concept of affordable housing for low- or moderate-income housing;
• Which communities services are targeted to low- or moderate-income individuals;
• Which activities promote economic development by financing businesses and farms that meet certain size eligibility standards;
• Which activities earn credit for revitalizing or stabilizing certain areas;
• Suggestions for documenting CD activities;
• The current discussion regarding revisions to the CRA regulations relating the CD activities; and
• Much more.

WHO?

The recording is designed for management of the loan department, Compliance Officers, CRA Officers, marketing staff and auditors.