Community Reinvestment Act (CRA) Audit
Process and Methodology
NETBankAudit conducts an objective and independent evaluation of the written CRA compliance program, including testing for compliance with the CRA and Service Members Civil Relief Act (SCRA), and an evaluation of management information systems (MIS). The audit is based on Large Institution Examination Procedures published by the OCC, FRB, and FDIC, as well as ongoing FFIEC and CFPB guidance. Sampling, if required, uses COSO criteria.
The CRA requires federally insured banks and thrifts to help meet the credit needs of their entire community, including low- and moderate-income neighborhoods, consistent with safe and sound operations. The audit methodology reflects the 1995 regulatory revisions, which emphasize performance and establish different evaluation tests for large, small, wholesale, and limited purpose institutions.
Scope of the Audit
- Evaluation under the applicable lending, investment, and service tests within each delineated assessment area
- Review of technical compliance, including reporting requirements
- Assessment of loan distribution by reviewing loan files, bank reports, or other analyses
- Evaluation of community development loans, qualified investments, and community development services
- Review of performance context information from community, government, civic, and other sources
The objective is to confirm compliance with CRA and satisfactory performance. A detailed report and supporting workpapers are provided upon completion.