Independent Banker - November 2022 - 39

Community bank
perspectives on
CRA reform
" One thing that stands out is the
change in data reporting, " says
Maureen Busch, vice president
and compliance and CRA
officer for The Bank of Tampa,
a $3.3 billion-asset community
bank in Tampa, Fla. " We would need to revamp our processes to
extract CRA data from our core system. The change from a bright
line test of a transaction threshold and location in specific fields
on the call report to gross annual revenues has the potential to
be problematic.
" The NPR, in its current form, leaves room for more clarification, "
she continues. " For instance, in the definitions of key terms and
how certain activities like community development loans and
investments will be weighted. While it may not cause any changes
to our current program activities, we are encouraged to see some
categories expanded, like community development activities. "
Busch expressed what she'd like to see for the NPR going
Quentin
Leighty
forward. " Keeping some quantitative evaluation of CRA could
be beneficial as metric-driven evaluation could miss some very
important data. "
Quentin Leighty, chief financial officer of $555 million-asset
First National Bank of Las Animas and president of the community
bank's Monument and Flying Horse, Colo., offices, also sees some
benefits and drawbacks to the NPR. " We believe the expansion
of activities outside the designated assessment area is a positive
change, " he says. " We welcome more clarity on that to be sure
we are effectively devoting resources in our community. We
have some concerns about a 60-day implementation period.
Community banks would benefit from a longer period to
implement the changes effectively.
" We're in a somewhat unique position as we broke through
the threshold and moved into the Intermediate Small Bank
category a couple of years ago, " he adds. " Under the NPR and
the $600 million threshold, we would actually now revert to a
Small Bank for CRA. We think that's appropriate for us because we
haven't changed much as an organization in that time period, but
the pandemic caused dramatic increases in assets. "
Leighty says First National Bank of Las Animas plans to continue
its good work. " CRA for us is 'telling the story,' " he says. " We serve
our entire community, including areas of low-to-moderate income,
minority communities and businesses. "
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Independent Banker - November 2022

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