If we have the public file available for every employee on their desktop, do I still need a hard copy in the main office?

As long as you can produce a copy of the electronic file upon request, you should be able to maintain it electronically. Banks have done this for years.

Ours is on the intranet for everyone to access and provide a copy upon request. That way I know they can only get to the most current version.

Follow up question: If you place you entire Public File on your bank's intranet for all employees to access, do you still need the "branch public file"?

Nope, if someone were to ever request it they get the whole thing.

Good to know. I was under the assumption that we would give a branch file to anyone requesting at a branch office, and the whole file for main office requests.

I agree with RR Jen. The branch file is really just designed as an abbreviated file as consumers always have the opportunity to review the entire file, regardless of which branch they come in. From the rule:

(c)Location of public information. A bank shall make available to the public for inspection upon request and at no cost the information required in this section as follows:

(1) At the main office and, if an interstate bank, at one branch office in each state, all information in the public file; and

(2) At each branch:

(i) A copy of the public section of the bank's most recent CRA Performance Evaluation and a list of services provided by the branch; and

(ii) Within five calendar days of the request, all the information in the public file relating to the assessment area in which the branch is located.


If you provide the entire file at each branch (such as through electronic means), there isn't a need for an abbreviated (branch) version.