I have read a nys law on CRA public file requirements. It stated in TItle 3. section 76.5 that "the department will prepare a written summary of the results of such assessment. The CRA rating and the written summary will be made available to the public. In addition, each banking institution shall include a copy of such rating and the three most recent summaries in the banking institution's public file as required to be maintained by Federal CRA regulations".

What I am concerned about is the last part. According to Reg. BB, banks are required to make available a copy of the public section of the bank's most recent CRA performance evaluation within 30 days of receipt.

What law do I have to follow? My bank's CRA compliance is examined by both FDIC and NY state banking department. what performance evaluation should be kept in the CRA public file?

Thank you.

As a state regulated bank, you will have to follow both federal and state law.

cgdiamond - Have you gotten additional feedback on this? I question whether or not we need to include the three most recent, when Federal CRA regulations clearly only require the most recent.