Community Reinvestment Act
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Community Reinvestment Act

Representative Engagements

Scrutiny of CRA compliance and performance is an ongoing regulatory, strategic and reputational risk for US banks. Banks are routinely assessed for CRA performance, with disclosed exam ratings and public opportunities for CRA performance matters to be raised and considered in the context of regulatory filings for charter acquisitions and growth initiatives. Insufficient CRA plans, programs and performance can impede bank strategic growth plans subject to regulatory review.


Promontory’s CRA practice is based on aligning compliance objectives with business models and management’s goals for growth and reputation risk management. The strength of our practice is our ability to quickly assess an institution’s core capacities to excel in CRA performance and propose compliance strategies that are responsive to community needs and designed to meet performance rating objectives. Our clients include banks in formation, limited purpose institutions, and small and large retail banks.

Our CRA practice professionals have years of experience as compliance examiners, supervisory policy makers and CRA program managers. They have designed and executed compliance programs, have written agency rules and guidance, and are conversant with a broad array of external CRA stakeholders. We have worked successfully with institutions facing regulatory challenges, banks filing charter or acquisition applications, and entities establishing or assessing their CRA programs.

Representative Engagements

  • Development of a CRA strategic plan for a limited purpose bank  
  • Development of a CRA plan as part of a business plan submission of an acquiring retail bank  
  • Conducting CRA exam readiness and self-assessment reviews  
  • Preparing a remedial plan for an institution subject to an adverse CRA rating  
  • Assisting a large bank in developing CRA program administration controls, governance structures, planning processes and performance reporting 

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