Department News COMPLIANCE
CRA Public File Update Time By Bryan Bradley, CRCM, Vice President of Compliance Services
One of the less complicated “compliance” requirements is kept up to date. Te regulatory requirements for each federal functional regulator follow.
• Federal Deposit Insurance Corporation — 12 CFR 345.43 • Federal Reserve Board — 12 CFR 228.43 • Office of the Comptroller of the Currency — 12 CFR 25.43
Content Requirements Te contents of the public file must be updated by April 1 of each year, unless the regulation provides different deadlines for specific file content requirements. Content requirements that must be placed in the file other than by April 1 follow.
All Banks • all written comments received from the public for the current year and each of the prior two calendar years, as well as any response to such comments by the bank
• a copy of the public section of the bank’s most recent CRA Performance Evaluation — Many banks include a long history of prior PEs, yet only the most recent is required. It must be placed in the file within 30 business days aſter receipt from the bank’s regulator.
• a list of branches, their street addresses and geographies (census tract of each location)
• a list of branches opened or closed during the current year and each of the prior two calendar years, along with their street addresses and geographies
• a list of services, hours of operations, available loan and deposit products and transaction fees generally offered by the bank’s branches, along with material differences in the availability or cost of services at particular branches, if any
• a map of each assessment area that shows the boundaries of the area and the geographies within the area; geographies may appear on the map or on a separate list • any other information that the bank chooses
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Small Banks • quarterly loan-to-deposit ratio for the prior calendar year • consumer loan information for the prior two calendar years if the bank elects to have one or more categories of such loans considered under the lending test, as well as the CRA Disclosure Statement, which must be placed in the file within three business days of receipt
Large Banks • consumer loan information for categories of such loans the bank has elected to be considered under the lending test — Te information shall be for each of the prior two calendar years and include the number and amount of loans by income categories, income geographies and in/out of the bank’s AA. Also, the CRA Disclosure Statement must be placed in the file within three business days of receipt.
HMDA Banks • written notice that the bank’s HMDA Disclosure Statement may be found on the Consumer Financial Protection Bureau’s website
Tere are two additional content requirements for banks with “strategic plans” or those with less than satisfactory ratings.
Conclusion All applicable content previously noted shall be placed in the bank’s public file for its “main” office. For branch office public files, a bank needs to only include the public version of its most recent PE and a list of services provided by the branch.
Once you have the file updated, sit back, relax and wait for all the public requests to review it.
This article is for information purposes and does not contain or convey legal advice. The information should not be used or relied upon in regard to any particular situation without consultation with your bank attorney. MBA Compliance Services and its Compliance Force program offer various programs to aid banks with compliance needs. For more information, call 573-636-8151.
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