Is the statement of condition still required to be kept within the bank?

Statement of condition??

We have some confusion on whether we need to retain the Statement of Condition/Annual Disclosure Statement. I know that the FDIC has proposed to remove its regulations relating to the disclosure. We are a Federal Reserve Bank, and I thought this requirement was rescinded by the Fed back in early 2000. However, we have a Compliance Consulting business telling us we need to keep those in our branches and retain permanently. I thought all that was available online now. Maybe I am missing something?

https://www.fdic.gov/regulations/laws/rules/2000-7300.html

Posting a notice and making it available - yes. Retain permanently - well it is just a portion of your call report which you would.

The FDIC published a proposal to rescind Part 350 on October 25, 2018, with a comment period ending November 26, 2018, indicating that the FDIC felt the rule is outdated by internet availability of all the same info. The final rule hasn't been issued as of March 13, 2019. It could come any time.

The final rule is here:
https://www.federalregister.gov/document...nonmember-banks

I'm no lawyer, so maybe someone can clarify. Does this rule apply to a State-Chartered, FDIC-Insured Bank? I don't understand this statement from the final rule.....

"Upon the removal of the regulations, all insured state nonmember banks and insured state-licensed branches of foreign banks (collectively, “banks”) would no longer be subject to the annual disclosure statement requirement set out in the existing regulations."

Yes, this applies to state charter, FDIC insured institutions. It removes the requirement to publish their annual statement (a modified CALL report). The other regulators killed this requirement years ago.

OK thanks DD. So if I may, does this mean we can take down the Notice hanging on our wall by the front door? And what about the CRA book contents??

Yes, you can take down the poster, but technically not until the effective date.

I'm not sure what you mean by the CRA book contents.

Nope, that answered my question Dave, thanks. I thought that notice was in our CRA Community Binder too and it's not.