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#2191622 - 09/05/18 12:32 PM Fees for accounts in CRA branches
corporate audit Offline
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Joined: May 2008
Posts: 31
During a recent audit it was found that branches in a CRA area are charging lower OD and NSF fees than branches in a non-CRA area. Is there any problem with that?

Thanks in advance.

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CRA
#2191623 - 09/05/18 12:36 PM Re: Fees for accounts in CRA branches corporate audit
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 77,237
Galveston, TX
Considering ODs are credit under Regulation B - charging customers different amounts might represent a fair lending issue. I am not really sure what a CRA area might be however.
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#2191637 - 09/05/18 02:54 PM Re: Fees for accounts in CRA branches corporate audit
corporate audit Offline
Junior Member
Joined: May 2008
Posts: 31
The CRA area mentioned means that branch is located in a low income area.

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#2192243 - 09/11/18 08:20 PM Re: Fees for accounts in CRA branches corporate audit
Princess Romeo Offline

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Princess Romeo
Joined: Jun 2001
Posts: 8,272
Where the heart is
Is the lower fee charge in LMI branches a conscience effort by the bank to provide lower costs services to LMI residents? I would recommend a legal review to determine if this should be done under a "special purpose credit program" since the benefit is in LMI areas and likely to be higher minority areas. If you are a Large Bank, you can then highlight it under your Services test.
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#2196098 - 10/22/18 06:39 PM Re: Fees for accounts in CRA branches corporate audit
mrogersfib Offline
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Joined: Aug 2018
Posts: 116
Agree with Princess that this would present favorably under CRA's service test. Such a behavior would not be a critical deciding factor in your exam rating, but would rather a qualitative factor for examiners to consider when evaluating the banks responsiveness to its customers.

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