Publisher Mike Welch's column of July 3 on the topic of CRA motivated me to compose this response. I am writing as one who is very familiar with this topic, having served as a successful CRA Compliance Officer for over 12 years. It is interesting how so many view CRA as a bad idea. Case in point: Banks don't like it but want credit unions to have it. Credit unions don't have it and want to make sure they don't get it. On the other hand, politicians and members of self-proclaimed do good activist groups view CRA as a cure all for society's woes. Indeed, these folks are convinced that while billions in tax dollars over decades have not eradicated inequities and injustices, the force feeding of CRA to federally insured financial institutions will surely do the trick. I can tell you that trying to deliver affordable services to low and moderate income households is an expensive, difficult and often a frustrating undertaking. The efforts of my former employer were truly noble, yet they impacted only a handful of individual households. In part, that can be traced to the fact that more effort is spent on documenting the institution's efforts than is spent on delivering services. To a large degree, CRA really translates into "CYA (cover your a_ _)" overkill. I mentioned frustration earlier. Permit me to elaborate. All to frequently the good efforts of federally insured institutions are cited by community groups and politicians as being inadequate or not affordable. (By the way, the references to not affordable always make me suspicious. I view these remarks as evidence that what our critics are really looking for is grants and charity not affordable services.) As an industry we are wise to stay away from CRA. Perhaps we can best accomplish this by following a simple three-prong approach. First, we need to work hard to educate individuals from low and moderate income households within our fields of membership. Over the years, history has shown that individuals from these households need knowledge much more than they need a grant or charity. Thus, we can make the greatest impact by focusing on education. Incidentally, educational initiatives are often provided at far lower costs than say below market rate loans or discounted other services. Secondly, we must develop and effectively deliver low-cost (notice I did not say no cost) fundamental services. Underserved households don't need a security broker, PC home banking or credit card programs with frequent flier miles. Instead they just need access to the basics like ATM cards, life line checking accounts and affordable credit. Education and fundamental services will go a long way to keep the CRA boogeyman away. A final element is needed however. That is adequate documentation. Not "CYA" overkill, rather as Sergeant Joe Friday use to say: "Just the facts madam, just the facts". Documentation is an essential part of our CRA Stay Away strategy because no matter what we do and no matter how well it is done, our critics will never be satisfied. Rick Stout VP, Corporate Development Charter Oak FCU Groton, Conn.

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