#34: How to Ace Your Next CRA Data Integrity Exam!

As you know, before each exam, your regulators will conduct a review of your lending data to ensure that it is accurate enough to determine your lending performance. The regulators have a very specific approach that is delineated within the Consumer Compliance Handbook. If you haven’t downloaded this yet, I would encourage you to do so today. Here is the link and notation on where to find the specific framework within the several hundred page document. Consumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdf Use this as a guide for any size bank; regardless of regulator, these sampling procedures are universal. I suggest that you mimic this sampled approach on a periodic basis for your small business loans, small farm and HMDA loans. You can even use this same statistically sound approach to sample your community development loans, services and investments. The CRA sampling model employs a 5.0 percent precision level with a minimum 90.0 percent confidence. It’s prudent to have an independent review embedded into your CRA program to ensure data integrity! Happy sampling!Quotes• “[An independent review] means that whoever’s collecting this information, we should have someone else sampling and double checking.” (02:55-03:04)Want to learn more about the CRA? Sign up for CRA Today’s free course: https://hub.cratoday.com/freecourseLinksConsumer Compliance Handbook (Page 852-854): https://www.federalreserve.gov/boarddocs/supmanual/cch/cch.pdf CRA Today Website: https://cratoday.com/ For more information on the CRA Hub, a membership for bankers to connect, inspire, and master the art of CRA: https://cratoday.com/hub/ Copyright © 2021 by CRA Today LLC(No claim to original U.S. government material)All rights reserved. No part of this podcast may be reproduced, stored in a retrieval system, or transmitted in any form or by any means, including electronic, mechanical, photocopying, recording, or otherwise, without prior written permission of the author and publisher.This podcast is a periodic publication of CRA Today LLC and is intended to notify and inspire recipients of new developments in the Community Reinvestment Act. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.Podcast production and show notes provided by HiveCast.fm