Federal bank examiners (FDIC, OCC, FRB) are responsible for evaluating bank’s CRA activities and overall performance. This CRA Evaluation (or “Exam”) is not necessarily scheduled in conjunction with, and may be conducted less frequently than the Compliance Examination. For example, the bank’s compliance examination may occur every 2 years and the CRA exam may occur every 4 years. It appears that compliance with CRA has become less important.
But don’t be misled - when the examiners appear, they may expect the bank to produce 4 years of loan reports, community development activities (including qualified investments, services, and loans). As the CRA Officer, it is important to manage and document CRA activities on an ongoing basis, and not just when “the CRA examiner is coming”!!