Home / Helping a Bank Achieve Compliance with Proposed CRA Rules
Our banking client sought help to address a significant regulatory shift stemming from the proposed Community Reinvestment Act (CRA) rules. The modernized rules outline more stringent and expansive requirements to how banks evaluate their obligations to low- and moderate-income communities. The bank, regulated by the OCC, needed to transition from manual data management systems to more sophisticated tools while overhauling its compliance processes.
Although not out of compliance with the prior CRA rules, the client sought to proactively adapt to the increased requirements; however, their internal teams lacked the capacity for such a large-scale regulatory transition, leading them to engage SolomonEdwards to help them navigate the changing requirements.
Our team supported the bank in three key areas:
The client selected a new compliance software to manage community development data more effectively. Transitioning from Excel, this system streamlined data tracking and addressed the expanded data requirements of the updated CRA regulations.
To assess readiness, we applied the new rules to historical data, simulating compliance scenarios. This “test drive” provided valuable insights into potential challenges and highlighted areas needing adjustment under the revised framework.
Our CRA subject matter experts analyzed the extensive 1,500-page regulation, comparing its requirements with the prior rules. Collaborating with our business analysts, they documented business requirements, redesigned processes, and laid the foundation for implementing new compliance procedures.
Our role expanded beyond project management to include a team of CRA experts and business analysts, ensuring that every aspect of the compliance initiative—from interpretation to execution—was meticulously managed.
Despite a legal injunction pausing the implementation of the CRA rules and delaying the official compliance deadline to at least 2027, our client decided to proceed with the project. This proactive stance has allowed them to refine their systems and gain a competitive edge in meeting the evolving regulatory requirements with enhanced tools, processes and expertise in place.
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