Thread Options
|
#2118083 - 02/13/17 10:20 PM
CRA Public Notice revised
|
Member
Joined: Jan 2016
Posts: 69
|
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.
|
Return to Top
|
|
|
|
#2118215 - 02/14/17 07:46 PM
Re: CRA Public Notice revised
Claudia M
|
Power Poster
Joined: May 2003
Posts: 3,760
Running and riding everywhere ...
|
I'm not aware of any changes, I make sure mine matches up with the model language in the regulation.
_________________________
I don't need any more negativity in my life...be positive and helpful people or I will kick you in the shins!!!
|
Return to Top
|
|
|
|
#2118218 - 02/14/17 07:54 PM
Re: CRA Public Notice revised
Claudia M
|
10K Club
Joined: Jul 2001
Posts: 83,396
Galveston, TX
|
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
|
Return to Top
|
|
|
|
#2118219 - 02/14/17 08:06 PM
Re: CRA Public Notice revised
Claudia M
|
Diamond Poster
Joined: May 2013
Posts: 1,783
The Mitten State
|
They also added You may also submit comments electronically through the FDIC website at www.fdic.gov/regulations/cra
_________________________
Nonsense wakes up the brain cells.
--Dr. Seuss
|
Return to Top
|
|
|
|
#2118239 - 02/14/17 09:12 PM
Re: CRA Public Notice revised
Claudia M
|
Diamond Poster
Joined: May 2013
Posts: 1,783
The Mitten State
|
So the information regarding comments electronically only applies to FDIC banks?
_________________________
Nonsense wakes up the brain cells.
--Dr. Seuss
|
Return to Top
|
|
|
|
#2118272 - 02/14/17 11:06 PM
Re: CRA Public Notice revised
Claudia M
|
Power Poster
Joined: May 2003
Posts: 3,760
Running and riding everywhere ...
|
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.
_________________________
I don't need any more negativity in my life...be positive and helpful people or I will kick you in the shins!!!
|
Return to Top
|
|
|
|
#2118274 - 02/14/17 11:08 PM
Re: CRA Public Notice revised
Claudia M
|
Power Poster
Joined: May 2003
Posts: 3,760
Running and riding everywhere ...
|
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.
_________________________
I don't need any more negativity in my life...be positive and helpful people or I will kick you in the shins!!!
|
Return to Top
|
|
|
|
#2118278 - 02/15/17 12:55 AM
Re: CRA Public Notice revised
RR Jen
|
Platinum Poster
Joined: Jul 2004
Posts: 505
WA
|
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.
|
Return to Top
|
|
|
|
#2118286 - 02/15/17 12:44 PM
Re: CRA Public Notice revised
Claudia M
|
10K Club
Joined: Jul 2001
Posts: 83,396
Galveston, TX
|
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 .
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com
|
Return to Top
|
|
|
|
#2118305 - 02/15/17 03:06 PM
Re: CRA Public Notice revised
Claudia M
|
Power Poster
Joined: May 2003
Posts: 3,760
Running and riding everywhere ...
|
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.
_________________________
I don't need any more negativity in my life...be positive and helpful people or I will kick you in the shins!!!
|
Return to Top
|
|
|
|
#2118306 - 02/15/17 03:09 PM
Re: CRA Public Notice revised
Claudia M
|
100 Club
Joined: Oct 2013
Posts: 221
Midwest
|
There's no PDF of the notice available from the FDIC, right?
|
Return to Top
|
|
|
|
#2118310 - 02/15/17 03:12 PM
Re: CRA Public Notice revised
Claudia M
|
Power Poster
Joined: May 2003
Posts: 3,760
Running and riding everywhere ...
|
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.
_________________________
I don't need any more negativity in my life...be positive and helpful people or I will kick you in the shins!!!
|
Return to Top
|
|
|
|
#2118319 - 02/15/17 04:06 PM
Re: CRA Public Notice revised
Claudia M
|
Platinum Poster
Joined: Jul 2004
Posts: 505
WA
|
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.
|
Return to Top
|
|
|
|
#2118570 - 02/16/17 08:40 PM
Re: CRA Public Notice revised
Claudia M
|
Power Poster
Joined: Jun 2001
Posts: 8,272
Where the heart is
|
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.htmlI 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.
_________________________
CRCM,CAMS Regulations are a poor substitute for ethics. Just sayin'
|
Return to Top
|
|
|
|
#2118580 - 02/16/17 09:19 PM
Re: CRA Public Notice revised
Claudia M
|
10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
|
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.
_________________________
John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
|
Return to Top
|
|
|
|
#2118582 - 02/16/17 09:24 PM
Re: CRA Public Notice revised
Claudia M
|
10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
|
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.
_________________________
John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
|
Return to Top
|
|
|
|
#2118585 - 02/16/17 09:35 PM
Re: CRA Public Notice revised
Claudia M
|
10K Club
Joined: Oct 2000
Posts: 40,086
Cape Cod
|
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.
_________________________
John S. Burnett BankersOnline.com Fighting for Compliance since 1976 Bankers' Threads User #8
|
Return to Top
|
|
|
|
#2119602 - 02/27/17 03:17 PM
Re: CRA Public Notice revised
Claudia M
|
Diamond Poster
Joined: Jul 2006
Posts: 1,115
Where the Green Grass Grows
|
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
|
Return to Top
|
|
|
|
#2119605 - 02/27/17 03:37 PM
Re: CRA Public Notice revised
Claudia M
|
Platinum Poster
Joined: Aug 2015
Posts: 756
Land Lacking in Lakes, IL
|
Thanks for the information,everyone! Just got ours updated.
_________________________
"Pressure is something you feel when you don't know what you're doing" - Peyton Manning
|
Return to Top
|
|
|
|
#2119618 - 02/27/17 04:49 PM
Re: CRA Public Notice revised
Claudia M
|
Diamond Poster
Joined: Dec 2013
Posts: 1,399
CA
|
Had no idea until I got Banker's Compliance Consulting blog this morning. No FIL???? seriously??
_________________________
The opinions expressed are mine, do not represent the opinions of my employer, and they are not to be taken as legal advice.
|
Return to Top
|
|
|
|
#2120299 - 03/02/17 07:40 PM
Re: CRA Public Notice revised
Claudia M
|
New Poster
Joined: Jun 2015
Posts: 3
|
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".
|
Return to Top
|
|
|
|
#2120340 - 03/02/17 10:29 PM
Re: CRA Public Notice revised
Claudia M
|
New Poster
Joined: Jun 2015
Posts: 3
|
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!!
|
Return to Top
|
|
|
|
|
|