QUESTION: A question was asked on-line verifying the location of CRA files, specifically main office and branch offices. The
response was that the 'extra thick file' that is required to be in the main office and at least one branch of each MSA. Please help me with this, I have searched Reg BB, 228.42(c). This section and the answer provided do not seem to match.
ANSWER: There seems to be some confusion between requirements of CRA and requirements of HMDA (Reg C). CRA requires that your main public file (the thick one) be available at your main office. That file includes your HMDA Disclosure Statements for the past two years. In addition, this thick CRA file must also be available in at least one office in any other states where you have branch offices other than your home state. The branch CRA public file (which only needs to contain a copy of the most recent CRA Public Evaluation and a list of hours and services offered at the branch) must be available in each branch office other than the ones where the main file is located.
HMDA used to require that the HMDA Disclosure statements be available at the main office and in at least one office in each MSA where the bank had offices. Now that's been modified to provide an additional option. Instead of this requirement an institution can post the address for sending written requests for the disclosure statement in the lobby of each branch located in an MSA where the institution has offices and mailing or delivering a copy of the HMDA Disclosure statement within 15 calendar days of receipt of the request. In either case, the institution must post a general notice about the availability of HMDA data in each office located in an MSA where the institution has offices.
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