Case Study: Targeted CRA Gross Annual Revenue Review

Big Picture

The Community Reinvestment Act (CRA) encourages financial institutions to meet the credit needs of all their communities, particularly low- and moderate-income neighborhoods. The Federal Reserve, the Office of the Comptroller of the Currency (OCC), and the Federal Deposit Insurance Corporation (FDIC) evaluate banks on their lending record in various community segments. This evaluation plays a role in a bank’s overall CRA rating, which can then influence their ability to expand operations. To achieve a high CRA rating, banks must keep accurate records of their loan data.

CRA Targeted CRA GAR Review

Client Scenario

A midsized regional bank sought a qualified third-party to ensure the validity of their CRA Loan Register (LR) data, particularly the critical gross annual revenue field. However, they lacked the resources to complete this validation in the allotted timeframe. They found a solution in Asurity Advisors. 

Asurity Solutions

Asurity Advisors conducted a targeted review of the gross annual revenue field data to verify its accuracy and consistency with regulatory guidelines for all CRA-reportable loans. This focused approach ensured efficient use of resources while addressing the bank’s key concern. Recognizing the importance of data integrity, Asurity Advisors conducted a rigorous 20% quality control review on the reviewed data population. Where discrepancies were identified, Asurity Advisors proposed data updates to ensure the bank’s submission aligned with CRA reporting requirements. Asurity Advisors’ comprehensive review process significantly increased the bank’s confidence in the accuracy of their CRA data and assisted the institution in mitigating the risk of potential regulatory inquiries or penalties related to inaccurate CRA reporting.