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#2118083 - 02/13/17 10:20 PM CRA Public Notice revised
Claudia M Offline
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I had a while back found some info on the revisions to the CRA Public Notice, but I think I am missing one and have looked on the Internet but cannot seem to find anything that summarizes the recent changes or has an example notice with the changes.

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#2118215 - 02/14/17 07:46 PM Re: CRA Public Notice revised Claudia M
RR Jen Offline
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I'm not aware of any changes, I make sure mine matches up with the model language in the regulation.
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#2118218 - 02/14/17 07:54 PM Re: CRA Public Notice revised Claudia M
rlcarey Offline
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#2118219 - 02/14/17 08:06 PM Re: CRA Public Notice revised Claudia M
JWills, CRCM Offline
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They also added

You may also submit comments electronically through the FDIC website at www.fdic.gov/regulations/cra
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#2118234 - 02/14/17 08:55 PM Re: CRA Public Notice revised Claudia M
RR Jen Offline
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https://www.gpo.gov/fdsys/pkg/FR-2017-01-18/html/2016-31928.htm

Found it for FDIC banks...not seeing anything for FRB (which we are).
Last edited by RR Jen; 02/14/17 08:58 PM.
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#2118239 - 02/14/17 09:12 PM Re: CRA Public Notice revised Claudia M
JWills, CRCM Offline
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So the information regarding comments electronically only applies to FDIC banks?
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#2118272 - 02/14/17 11:06 PM Re: CRA Public Notice revised Claudia M
RR Jen Offline
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I'm not sure...I'm just not sure why a FRB bank would insert a comment saying to send comments to the FDIC. I had no luck finding any such update to the FRB model language that Randy posted. Not saying there isn't any, but my Google skills aren't locating it.
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#2118274 - 02/14/17 11:08 PM Re: CRA Public Notice revised Claudia M
RR Jen Offline
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e-CFR data is current as of February 10, 2017



Title 12 → Chapter II → Subchapter A → Part 228 → Subpart C → Appendix





Title 12: Banks and Banking
PART 228—COMMUNITY REINVESTMENT (REGULATION BB)
Subpart C—Records, Reporting, and Disclosure Requirements


Appendix B to Part 228—CRA Notice

(a) Notice for main offices and, if an interstate bank, one branch office in each state.

Community Reinvestment Act Notice

Under the Federal Community Reinvestment Act (CRA), the Federal Reserve Board (Board) evaluates our record of helping to meet the credit needs of this community consistent with safe and sound operations. The Board also takes this record into account when deciding on certain applications submitted by us.

Your involvement is encouraged.

You are entitled to certain information about our operations and our performance under the CRA, including, for example, information about our branches, such as their location and services provided at them; the public section of our most recent CRA Performance Evaluation, prepared by the Federal Reserve Bank of ____ (Reserve Bank); and comments received from the public relating to our performance in helping to meet community credit needs, as well as our responses to those comments. You may review this information today.

At least 30 days before the beginning of each quarter, the Federal Reserve System publishes a list of the banks that are scheduled for CRA examination by the Reserve Bank in that quarter. This list is available from (title of responsible official), Federal Reserve Bank of ____ (address). You may send written comments about our performance in helping to meet community credit needs to (name and address of official at bank) and (title of responsible official), Federal Reserve Bank of ____ (address). Your letter, together with any response by us, will be considered by the Federal Reserve System in evaluating our CRA performance and may be made public.

You may ask to look at any comments received by the Reserve Bank. You may also request from the Reserve Bank an announcement of our applications covered by the CRA filed with the Reserve Bank. We are an affiliate of (name of holding company), a bank holding company. You may request from (title of responsible official), Federal Reserve Bank of ____ (address) an announcement of applications covered by the CRA filed by bank holding companies.
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#2118278 - 02/15/17 12:55 AM Re: CRA Public Notice revised RR Jen
Moman Offline
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There may be confusion over the FRB - the FED still has responsibility for CRA; it didn't shift to the CFPB along with most of the other regs. The email address and mail to address appears to have changed for FDIC-regulated banks only; at least that's the way I read it - we are also an FRB regulated bank.

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#2118286 - 02/15/17 12:44 PM Re: CRA Public Notice revised Claudia M
rlcarey Offline
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Actually, each prudential regulator has their own CRA regulation.


12 CFR Part 25

12 CFR Part 195

12 CFR Part 228

12 CFR Part 345
.
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#2118305 - 02/15/17 03:06 PM Re: CRA Public Notice revised Claudia M
RR Jen Offline
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Correct....which is why I had the link to the FDIC with new language and then added the difference from the FRB. Everyone should check with their regulators model notice.
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#2118306 - 02/15/17 03:09 PM Re: CRA Public Notice revised Claudia M
NoJustNo Offline
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There's no PDF of the notice available from the FDIC, right?

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#2118310 - 02/15/17 03:12 PM Re: CRA Public Notice revised Claudia M
RR Jen Offline
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Not that I'm aware of, you need to put in the appropriate addresses. I've always just dumped the model language into a Word doc.
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#2118319 - 02/15/17 04:06 PM Re: CRA Public Notice revised Claudia M
Moman Offline
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That's what I have always done as well. There's a main office version and branch version of this disclosure. Be sure you use the right version at the correct location.

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#2118520 - 02/16/17 06:21 PM Re: CRA Public Notice revised Claudia M
JWills, CRCM Offline
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Thank you everyone. After all of this, I don't need to revise my notice at all. smile
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#2118570 - 02/16/17 08:40 PM Re: CRA Public Notice revised Claudia M
Princess Romeo Offline

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What I heard is that the FDIC made an internal change to the title in their regional offices from "Regional Manager" to "Regional Director", so state non-member banks need to update their CRA Lobby notices accordingly.

I am looking for confirmation of that on the FDIC's site but haven't found it yet. The reference to the CRA notice in the FDIC Rules and Regulations still shows "Regional Manager"
https://www.fdic.gov/regulations/laws/rules/2000-6700.html#fdic2000appendixbtopart345

but the FDIC Directory clearly states they are Regional Directors.
https://www.fdic.gov/regulations/community/cra_contacts.html

I have a call in to our FDIC field office to clarify and confirm the Lobby notice requirement.
Last edited by Princess Romeo; 02/16/17 08:45 PM.
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#2118580 - 02/16/17 09:19 PM Re: CRA Public Notice revised Claudia M
John Burnett Offline
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The FDIC is notorious for not updating its regulations on its own website. But if you go to the ecfr copy of Appendix B to Part 345, you will see that "Regional Director" appears eight times (four in the main office version, four in the branch office version), precisely in those locations in which "Regional Manager" appears in the version you see in the FDIC webpage. The ecfr version also ADDS in two places (one in each version) "You may also submit comments electronically through the FDIC's Web site at www.fdic.gov/regulations/cra."

The ecfr version reflects the changes made by the FDIC at the end of December (published at 82 FR 5356, Jan. 18, 2017).
Last edited by John Burnett; 02/16/17 09:30 PM. Reason: added something.
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#2118582 - 02/16/17 09:24 PM Re: CRA Public Notice revised Claudia M
John Burnett Offline
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What's bothersome is that the FDIC hasn't yet sent out an FIL announcing the change. That's a clear message to me that it isn't concerned about all the state non-member banks (remember, this is only for FDIC-supervised banks and savings associations) running around to update the CRA notices that no one reads (other than examiners and compliance officers).

Admittedly, this is the sort of thing that a still-wet-behind-the-ears newbie (yes, I know that's redundant) examiner will love to cite you for, but I can't get all worked up over it.

I'd put it on my "when I get a round tuit" list.
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#2118585 - 02/16/17 09:35 PM Re: CRA Public Notice revised Claudia M
John Burnett Offline
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The only regulator that made a change to its lobby notices is the FDIC. If you're a national bank, federal savings association or a state-chartered member bank, ignore this discussion.

Oh, sorry. You've already read down to here. Well stop here, then.
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#2118659 - 02/17/17 01:14 PM Re: CRA Public Notice revised John Burnett
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grin Thanks, John.
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#2119602 - 02/27/17 03:17 PM Re: CRA Public Notice revised Claudia M
Always In Training Offline
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We had made the FDIC manager to Director language change a little ways back when an address was updated. So, if you are FDIC, you may only need to add the:

You may also submit comments electronically through the FDIC website at www.fdic.gov/regulations/cra.

Why no FIL, FDIC????
Last edited by Always In Training; 02/27/17 03:19 PM. Reason: removed confusing clause
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#2119605 - 02/27/17 03:37 PM Re: CRA Public Notice revised Claudia M
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Thanks for the information,everyone! Just got ours updated.
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#2119618 - 02/27/17 04:49 PM Re: CRA Public Notice revised Claudia M
JC (Darth HMDA) Offline
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Had no idea until I got Banker's Compliance Consulting blog this morning. No FIL???? seriously??
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#2120299 - 03/02/17 07:40 PM Re: CRA Public Notice revised Claudia M
It depends! Offline
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I am perplexed by the last sentence in the revision. I do not know nor does the Federal Reserve know the title of the person to whom requests of an announcement of applications covered by the CRA filed by bank holding companies may be made. Does anyone anywhere know the answer to this??? I do not want to be replacing this numerous times to stay in compliance until someone formally provides us an answer. Any ideas???

"You may ask to look at any comments received by the FDIC Regional Director. You may also request from the FDIC Regional Director an announcement of our applications covered by the CRA filed with the FDIC. We are an affiliate of (name of holding company), a bank holding company. You may request from the (title of responsible official), Federal Reserve Bank of _______ (address) an announcement of applications covered by the CRA filed by bank holding companies".

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#2120340 - 03/02/17 10:29 PM Re: CRA Public Notice revised Claudia M
It depends! Offline
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Well, no one has had time to answer my question, but a message I left at the Federal Reserve in St. Louis was returned with an answer. The only reason she was able to return the call in the same day was having researched it out a couple of weeks ago. They use the term, "Officer in Charge of Community and Consumer Affairs". Of course, use the appropriate Fed Reserve for your area.
Maybe this will help some others out there!!

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