GeoDataVision
Regulatory Compliance Newsletter #3
 
These newsletters are intended to help you with regulatory compliance. GeoDataVision issues these advisories periodically.
The Biggest CRA mistake
    As any CRA officer knows, the Community Reinvestment Act does not specify quantitative performance standards. Rather, the regulation stipulates that bank performance will be rated using so-called "performance context" data. This term includes many factors such as local economic conditions, lender size and lender resources. Some of the most widely used performance context benchmarks include specific loan market data reported under HMDA and CRA. Penetration rates in the LMI tracts and LMI applicant market are some of the barometers that are especially important considerations. Other performance benchmarks would include lending to very small businesses ratios, Community Development lending, Assessment Area concentration factors, etc. Without this information it is very difficult to have a meaningful CRA self-assessment program. But until now, this data has not been readily available in a useful format to most bankers. Consequently, most CRA officers make the mistake of waiting for examiners to rate their peformance. This is one of the most fundamental mistakes a bank can make because the Community Reinvestment Act mandates that bankers meet the need for credit services in their community and demonstrate their performance. But how can you demonstrate your performance in light of performance context data you don't have?
New Reporting Tool

GeoDataVision now has developed an indispensible new tool to help CRA officers monitor and rate their bank's performance without waiting for regulators to show up for the CRA performance exam. GDV has compiled 12 reports that include the most important lending benchmark data in reports that are customized for your uniquely defined community. These Performance Benchmark Reports will be included in the Annual CRA Performance Analyses performed by GeoDataVision at no extra cost. However, for bankers who don't subscribe to the annual performance reviews, this data is available as a series of independent market reports for less than $1,000 for all 12 reports! There is no other tool like this anywhere else for anything close to the price. Moreover, the reports are full of valuable market data that will help you see your market as never before. Call 203-237-1332 or e-mail lensuzio@geodatavision.com for more information.
GeoDataVision