During a recent audit, it was recommended we place our CRA disclosure (the same one that's in the lobby) on our website. Should it be on every page? It would make the process a lot easier if it only needed to be on the pages pertaining to loan applications. Where is the CRA disclosure on your website?

CRA Disclosure? Are we talking about your CRA Notice (That one page document you hang in the branches) or the CRA LR disclosure?

I have neither on my website. It is not required. If audit wishes to have it on the site, ask them where in the reg that is covered This normally saves you the effort.

If you want a CRA statement (ie the CRA Notice) on the web, put it in your lending area....or have a nice "community involvement" page that marketing handles, with donations for the quarter, the notice, your current rating, etc., Much easier! That's the place someone looking for it would normally head anyhoo

I went back and reviewed the finding by internal audit. They are saying because the website accepts loan applications, it may be considered a "place of business" for HMDA purposes, triggering notice requirements. They recommend adding the CRA notice and public file availability of HMDA information to the website.

....It may be easier to just add the disclosures then argue about it. Is it Friday yet?????

Well sure, it might be easier to add the CRA and HMDA "Notice". I disagree with their findings, and still would ask for the cite, but that is up to you I prefer to do as necessary and not add other's interpretation of the reg to my world. Unless, again, you can find a cite that says the internet is a place of business...they're frankly wrong. I know of MANY MANY banks who are not in "compliance" with your auditor's findings Me included, and I won't be changing things any time soon.

But, you need to clairfy, do you want the CRA and HMDA Disclosure OR the Notice. We're talking the LR and the LAR when we say the "Disclosure" (modified in the case of the LAR) which is a large data file. There is a requirement to have one per MSA but not one per branch, which excludes their made up "internet" branch

Or are we talking the "Notices" which are one page...what we do and where ya get it" forms. Sure add them if you want. They are NOT required. That then becomes a business decision issue, so you can take it from there

First, a concrete cite would be nice, but these are virtual branches at best.

Second, I would recommend putting the notices there and linking from some common point. It isn't hard to do. It doesn't require a lot of maintenance. It does show your effort to inform the consumers.

It would be a subjective interpretation to actually cite it as a violation based on the limited knowledge I have of your transaction capacity and processes of taking web apps.

Dont' get me wrong I don't think the idea is all bad I just wouldn't do it "because" an auditor told me I had to. I personally don't want to maintain the information at this point online, but at some point I will perhaps. Again, it's all about that "business decision" verses a bad interpretation of the reg.