We are seeking an experienced Community Reinvestment Act professional to take primary ownership of a bank-wide CRA program. This is a senior, hands-on role for someone who can establish the framework for a growing institution, translate regulatory expectations into practical processes, and confidently represent the program with regulators, auditors, senior leadership, and community stakeholders.
The successful candidate will oversee CRA strategy, performance measurement, data quality, community development activity, regulatory reporting, and examination readiness. This person will also serve as the organization’s subject-matter expert when questions arise around CRA eligibility, performance expectations, or regulatory interpretation.
Because the program is being built and scaled, this role requires someone comfortable creating processes and methodologies rather than simply administering an established framework.
What You’ll Own
- Lead the overall CRA framework, including policies, procedures, controls, performance standards, and governance.
- Maintain and oversee the institution’s regulatory CRA plan, including goal development, updates, required approvals, public input, and regulatory submissions.
- Establish annual performance objectives and develop the supporting analysis used to determine appropriate targets.
- Create consistent standards for evaluating whether loans, investments, services, partnerships, and other activities receive CRA consideration.
- Provide guidance to business leaders on the CRA implications of new products, lending initiatives, partnerships, and strategic decisions.
- Prepare CRA updates and recommendations for senior management and Board-level committees.
Performance & Analytics
- Track results against established CRA objectives and identify potential performance gaps early.
- Develop forecasts and recommend corrective actions when performance is trending below expectations.
- Maintain reliable records covering CRA-eligible lending, investments, services, and employee activities.
- Prepare performance-context analysis and supporting documentation used during regulatory reviews.
- Evaluate economic, demographic, lending, and community-development trends that could affect CRA strategy.
- Translate quantitative and qualitative findings into actionable recommendations for leadership.
Data, Controls & Reporting
- Establish controls governing CRA data accuracy, completeness, classification, and documentation.
- Oversee processes involving geocoding, income and geography classifications, and community-development designations.
- Manage applicable CRA-related regulatory data submissions and reporting requirements.
- Maintain required public disclosures, notices, and CRA-related records.
- Partner with technology and data teams to improve reporting, automate controls, and strengthen data-quality processes.
- Ensure supporting records can withstand independent testing, audit, and regulatory review.
Community Development
- Develop relationships with nonprofit organizations, community-development groups, public agencies, and other relevant stakeholders.
- Assess community credit and development needs within the institution’s designated market area.
- Use community feedback and market analysis to inform CRA priorities and performance goals.
- Build and evaluate a pipeline of potential community-development loans, investments, services, and partnerships.
- Prioritize opportunities based on community impact, regulatory eligibility, and identified performance needs.
- Represent the institution at appropriate community-development meetings, forums, and industry events.
Regulatory Exams & Audit
- Serve as the primary CRA subject-matter contact during regulatory examinations.
- Coordinate examination materials, information requests, management interviews, and regulator communications.
- Explain and support the institution’s methodology, eligibility determinations, performance results, and documentation standards.
- Maintain examination-ready support for CRA-qualified activities.
- Lead responses to internal audit or independent testing findings, including remediation and validation.
- Monitor changes to CRA regulations, examination guidance, and supervisory expectations and translate them into appropriate program changes.
- Develop and deliver CRA training for employees and relevant business functions.
- Provide day-to-day direction and technical guidance to analysts and other contributors supporting the program.
- Establish clear standards for research, analysis, documentation, and qualification decisions.
- Coordinate employee community-development and volunteer initiatives where appropriate.
- Build broader organizational understanding of CRA responsibilities and performance objectives.
What We’re Looking For
- 8–10+ years of relevant experience in CRA, community development, or closely related bank regulatory compliance.
- Significant CRA experience within a banking environment, ideally including a nationally regulated institution.
- Prior responsibility for an entire CRA program or a substantial component of one, such as a CRA Officer, Deputy CRA Officer, or comparable senior practitioner.
- Strong working knowledge of federal CRA requirements, examination procedures, qualifying activity standards, and the regulatory framework applicable to strategic-plan institutions.
- Direct experience supporting or leading a CRA regulatory examination, including examiner requests, interviews, documentation, and regulatory discussions.
- Ability to independently make and support complex CRA qualification and regulatory interpretation decisions.
- Demonstrated experience developing methodologies, controls, procedures, and supporting documentation.
- Strong knowledge of CRA data, geocoding, demographic analysis, and regulatory reporting processes.
- Familiarity with HMDA, small‑business lending data, LMI analysis, or related regulatory datasets.
- Experience communicating CRA performance and regulatory matters to executives and Board-level stakeholders.
- Experience directing, mentoring, or reviewing the work of analysts or other compliance professionals.
Experience developing or modifying a CRA strategic plan, including regulatory submission and public-comment requirements, is highly desirable. A CRCM or comparable compliance credential is also preferred, as are established relationships within community-development organizations or networks.