CRA Support Services

Community banks face challenges meeting regulatory requirements. With rule changes and staff turnover, it can be difficult to determine the best path forward for your bank to fulfill community reinvestment goals and obligations, track them, and clearly communicate value to examiners. Our CRA Support Services can help bridge any gaps your bank may be facing and optimize your compliance efforts.


  • Conduct review of assessment area demographics, lending, branching, and Community Development activities

  • Develop performance context to include mitigating factors related to perceived deficiencies in performance

  • Provide detailed, written assessment following FFIEC CRA Exam Procedures (appropriate for your bank)

Assessment Area Analysis

  • Evaluate delineated assessment areas to determine appropriateness

Branch Distribution Analysis

  • Determine any issues with branch distribution relative to serving low- and moderate-income people and geographies

Peer Analysis

  • Determine bank “peers” for comparative purposes

Community Development Activity Evaluation

  • Review and evaluate loans, investments, donations, and services to determine CRA qualification as well as community impact

  • Ensure documentation and description demonstrates qualification and impact

Strategic Plan Development

  • Determine appropriateness of Strategic Plan option

  • Solicit public comments

  • Develop or update CRA Strategic Plan

CRA Action Plan

  • Help establish a meaningful and targeted approach to improving CRA performance at the institution, state, and product levels based on either self-identified deficiencies or less than satisfactory exam ratings

CRA Compliance Program Review

  • Review overall CRA program, including management reporting, goals, and deficiencies

  • Provide tangible recommendations for program enhancement

  • Provide action plan for implementing targeted results

CRA Ratings Appeal

  • Challenge CRA rating of “Needs to Improve” or “Substantial Noncompliance” within your regulator’s challenge criteria

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