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Find the Regulator
by Mary Beth Guard, BOL Guru

Your institution undoubtedly does a fine job of keeping customer addresses current and accurate. We hope you are just as careful when it comes to making sure you are using the correct regulatory addresses. For example, where are you sending your SARs? How about your CRA and HMDA submissions? What address are you showing for your regulator on your adverse action notices? Your CRA notices?

Take a quick inventory of all the areas where a government entity's address comes into play, then go to the agency's Web site to see if the address you're using is the right one.

If your institution has converted its charter, or you've gone through a merger, or you are a state-chartered bank that has recently become a member of the Federal Reserve, you need to update any notices and disclosures that mention primary federal regulator.

Even if your institution hasn't made a switch, there may still be a need for alteration because some regulatory addresses have changed.

For example, in October, 2001, the FFIEC announced address changes for HMDA and CRA data submissions to the Federal Reserve. On July 1, 2002, the FDIC centralized its consumer affairs function, necessitating an address change on adverse action notices for banks whose primary federal regulator is the FDIC to:

FDIC Consumer Response Center
2345 Grand Boulevard, Suite 100
Kansas City, Missouri 64108

The OCC changed its consumer complaint address in 1998.

Don't get caught with an address violation!

The original version appeared in the July 2002 edition of the Oklahoma Bankers Association Compliance Informer.

First published on BankersOnline.com 1/13/03



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