Case Study: CRA Strategic Plan

Big Picture

Opening a new branch creates many operational and regulatory challenges for banks of all sizes. A chief regulatory risk in opening a new branch includes the Community Reinvestment Act (CRA), which encourages institutions to invest in the communities in which they do business. When adding a branch, especially if it will be located outside of the bank’s lending footprint, CRA Officers and banks must perform detailed analysis to be prepared for regulatory scrutiny.

CRA Strategic Plan

Client Scenario

An OCC-regulated bank, facing a potential CRA exam in 2024, needed to ensure its existing CRA Strategic Plan positioned them for a successful review following a branch opening in a new geography.  Asurity Advisors partnered with the bank to proactively prepare for the upcoming CRA exam. The bank also asked Asurity Advisors to analyze the bank’s CRA Strategic Plan relative to the current and proposed branch locations and identify implications thereof.

Asurity Solutions

Asurity Advisors meticulously evaluated the bank’s existing documents to ensure that they accurately reflected the bank’s efforts in meeting CRA requirements when contemplating this new branch. Asurity Advisors also reviewed the CRA Strategic Plan to determine the best course of action—whether to continue operating under the existing plan, develop a new CRA Strategic Plan, or modify the current one.  This guidance ensured the bank adopted the most effective approach for achieving CRA compliance. 

By partnering with Asurity Advisors, the client gained the confidence and strategic direction needed to face the CRA exam.  This proactive preparation will minimize regulatory risk and ensure the bank continues serving its community effectively.