Thread Options
|
#1685064 - 04/03/12 01:27 PM
CRA public file
|
Power Poster
Joined: Apr 2005
Posts: 4,013
|
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?
|
Return to Top
|
|
|
|
#1685308 - 04/03/12 07:15 PM
Re: CRA public file
Trees
|
Power Poster
Joined: Apr 2005
Posts: 4,013
|
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.
|
Return to Top
|
|
|
|
#1685346 - 04/03/12 08:08 PM
Re: CRA public file
Trees
|
Power Poster
Joined: Apr 2005
Posts: 4,013
|
Rats. OK. Thanks for the clarification.
|
Return to Top
|
|
|
|
#1685350 - 04/03/12 08:11 PM
Re: CRA public file
Trees
|
10K Club
Joined: Dec 2000
Posts: 21,293
|
|
Return to Top
|
|
|
|
#1685994 - 04/05/12 01:28 PM
Re: CRA public file
Trees
|
Gold Star
Joined: Nov 2011
Posts: 378
Texas ...
|
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
_________________________
Can't is not an option.
|
Return to Top
|
|
|
|
#1686020 - 04/05/12 01:51 PM
Re: CRA public file
Trees
|
Gold Star
Joined: Nov 2011
Posts: 378
Texas ...
|
Thanks! I know that was probably a silly question, but I haven't had my coffee yet.
_________________________
Can't is not an option.
|
Return to Top
|
|
|
|
#1691185 - 04/20/12 06:52 PM
Re: CRA public file
Trees
|
Junior Member
Joined: Jul 2004
Posts: 28
|
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...
|
Return to Top
|
|
|
|
#1691761 - 04/24/12 02:34 AM
Re: CRA public file
Trees
|
Junior Member
Joined: Jul 2004
Posts: 28
|
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.
|
Return to Top
|
|
|
|
#1692106 - 04/24/12 07:00 PM
Re: CRA public file
Trees
|
Junior Member
Joined: Jul 2004
Posts: 28
|
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!
Last edited by Latitude 21; 04/24/12 07:01 PM.
|
Return to Top
|
|
|
|
#1696516 - 05/07/12 06:28 PM
Re: CRA public file
Trees
|
Diamond Poster
Joined: Dec 2008
Posts: 1,268
|
Is there anything in the physical public file that should not be included in an electronic public file?
|
Return to Top
|
|
|
|
#1696815 - 05/08/12 02:27 PM
Re: CRA public file
Trees
|
Diamond Poster
Joined: Dec 2008
Posts: 1,268
|
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.
|
Return to Top
|
|
|
|
|
|