Dear Dr. CRA –

We’re all waiting anxiously for word from Washington on the changes to the CRA.  While we’re waiting, is there anything I can do to be getting ready?

Sincerely,

Anxiously Awaiting New Rules

Dear Anxious,

We know it’s tough not knowing what to expect from the CRA reform process, but that doesn’t mean you can’t start thinking about how you’ll respond to the changes when they do come.  It’s a good time to review your CRA program to make sure you are prepared to implement any changes.  Some things to think about:

Plan to comment on any proposed changes.  When I hear a concern about a new rule, my first question is always “did you submit a comment?”  Far too often, the answer is “no.”  The agencies really do read all comments and want to hear about the impact of the proposed rule on your financial institution.  It’s important for everyone with an opinion to submit a written comment.  Detailed instructions for submitting comments will be provided in the proposal itself.

Create a strategy for interpreting and implementing the changes.  Do you have up-to-date policies and procedures for your CRA compliance program?  How will you amend and distribute the new procedures?  How will you communicate the changes to senior management?  How will you communicate the changes to lenders, branch managers, and other key staff?  Thinking through these questions beforehand and developing your plan can make the implementation phase more efficient and successful.

Receiving new rules can be a challenge, but I encourage you to also see it as an opportunity.  It could be your chance to raise awareness of your CRA program in your institution, to implement a strategy you’ve been wanting to try, and to re-engage your CRA stakeholders throughout the bank.  Use the new rules as your chance to re-evaluate your program and take it in a new direction!