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#2185092 - 07/12/18 01:49 PM Branch Notice Requirements
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,963
TN
I have what may be an elementary question. Our CRA/Fair Lending Officer has resigned and right now we are between officers. We are having an exam in August and need to update our signage to remove her name. Is having the name of the officer a requirement for CRA - or can we just have the title? All other information will remain the same.

Thank you!
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#2185099 - 07/12/18 02:01 PM Re: Branch Notice Requirements Skittles
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,643
Appendix B to Reg BB provides the sample notices which requests both a name and title. Therefore, I would list both. That said, I have seen many banks list the President as that position (typically) changes less frequently than the CRA Officer.

From Appendix B:
"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."
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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