The starting place for building a professional CRA Program includes:
- CRA Policy
- CRA Procedures
- CRA Data Entry Guide
- CRA Audit Checklist
- CRA Committee Agenda
- Documents and Worksheets
“Data Integrity” is critical for measuring and managing compliance and performance responsibilities. Data Entry Guides are essential tools to assure the consistent and correct coding of HMDA and CRA records.GeoDataVision Data Entry Guides are user-friendly and kept up to date with regulatory change.
Reports include an Excel spreadsheet documenting the HMDA and CRA files selected for testing and the results of the comparison of the application/file information to the LAR and Microdata file; each Excel spreadsheet will include a legend to reference the source document used to perform the review. Also, a sample of all source documents from one loan file used to review a LAR entry.
Documents Requirements for Data Review
HMDA Operating Procedures Application or Loan Specific:
- 1. Initial dated application.
- 2. Application to support borrower income and applicant information (race, sex, ethnicity).
- 3. Underwriting transmittal summary (if income is not supported by the application).
- 4. HMDA Worksheet if one was completed.
- 5. Documentation to support loan purchase type (if loan is not kept in portfolio).
- 6. Loan Note (if loan was made).
- 7. Adverse Action Letter (if application was denied).
- 8. Withdrawal email or other evidence of withdrawal from applicant (if application was withdrawn by the customer).
- 9. HOEPA letter or printout, if applicable.
If we are conducting an electronic review, prior to completing and submitting the draft spreadsheet with the results to the Bank, we will communicate with our point of contact at the Bank of any issues due to lack of documentation in order to obtain additional documentation necessary to complete or clarify the review. Obviously, if we are conducting an onsite review, the need for additional information will be addressed during the review. Hopefully this will enable the process to go smoothly and eliminate the need for multiple drafts of the review results.
Banks supply records with acceptable street, city, state, and zip code addresses for which we provide completed geocoding. Normal acceptance tolerance is 95%. Additional manual searches for more completeness can be done at additional charges.
GeoDataVision will assess the “Community Impact” and effects on deposit customers of the potential closing of a bank branch. Regulations mandate that a bank must submit “statistical or other information in support of the reasons consistent with the institution’s written policy for branch office closings”. Our reports cover important considerations in the process and supply a full written report with observations and conclusions.
A Community Needs Assessment is a market study conducted to help a bank identify and understand the need for financial services and community development within its Assessment Area. While not required by regulation, such an analysis will provide the bank with “performance context” which is the basis for establishing “performance standards”. Also, such a Report can be used and relied on by the bank when assessing its Community Development Needs.
This is an onsite review of the bank’s “processes and procedures” for maintaining and handling CRA, Fair Lending, and Community Development activity, including hardware and software, systems for collecting and recording data, and personnel at all levels.
Process & Procedures
- Data Processing
- Record Maintenance
- Sytems Analysis
GeoDataVision Webinars are recognized as some of the finest presentations available, for information to help banks meet their “compliance and performance” responsibilities. The experts that present the materials are some of the finest in the country. The topics covered include CRA, Fair Lending, HMDA, Exam Prep, and more. Available live and recorded.