At our main office we have the HMDA docs and the reports issued by the CRA examiners.

At our branches we have an internal report that includes all the pertinent info data, ie branches, locations and hours, types of loans, community involvement, special awards, etc.
Currently, we do not maintain a copy of the examiner issued reports at the branches.

We also have the requisite notices telling people how to obtain the info, etc.

Do we need to have a copy of the agency's CRA public report available at all of our branches?

Reg BB details what must be in the public file at the various locations:

http://www.bankersonline.com/regs/228/228-43.html

Kathleen, so working through all the sections and subsections, colons and subcolons, etc of the Reg, we are arguing over 228.43 (c(2). I say the reference to "at each branch" refers to the interstate branches referred to in (1). So, if you have branches in only one state, you need to keep the CRA performance eval. in the main office branch but other pertinent detail (not the eval.) in the other branches. A collegue is interpreting that to mean that the eval. needs to be maintained in each and every branch.

Please be the referee.

Thank you.

That means at each and every branch. The reference to the interstate branch means one of those gets the full file.

Or just make it available electronically and avoid all of the paper and upkeep. Everyone has everything and can produce as needed.

Rats. OK. Thanks for the clarification.

OK we have our hours of operations for all the branches listed in the CRA public file. What happens if our branch hours are not the same as what we have in the Public file? Is this any sort of violation? Of course what's posted vs what's in the public file needs to be the same but I just wanted to question this a little bit further.
Thanks

The file is supposed to be updated as of 4/1 each year. As things change during the year, many banks do update so that everything is accurate as of the time of an audit or exam.

Thanks! I know that was probably a silly question, but I haven't had my coffee yet.

Do the appendices to the Public Disclosure document also have to be included in the Public File? I've received conflicting opinions and have noticed that some of our peers have excluded those appendices from what's made available on request.

Thanks for the consult...

Are you asking about the CRA Exam report that is published or about the HMDA disclosure statement?

I'm referring to the FRB's CRA Performance Evaluation/Public Disclosure report. The appendix includes the Scope of Examination, Glossary of Terms and CRA Core Tables.

I have never seen a bank separate out sections of the report for its public file. It is made public anyway via all of the regulators' websites so you are not keeping anything confidential.

Thank you very much. As you can tell, I was puzzled too. I'm even wondering why the Public File is still required now that data and evaluations are accessible on the regulators' websites, but that's probably due to a 1970's regulation never being modernized. Thanks again!

It would take work to remove those sections...I don't like to create extra work!

Is there anything in the physical public file that should not be included in an electronic public file?

No. An electronic file should be the same thing as a paper file...just the format is different.

So, pretty much, after we set up the electronic CRA file, we can dispose of the physical file? Does anyone happen to have a list of banks with CRA files on-line so I can compare?

Thanks so much to all.