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#2256234 - 07/01/21 08:24 PM Consumer Complaints in the Public File?
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
How does one determine which complaints are placed in the CRA Public File?
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#2256235 - 07/01/21 08:28 PM Re: Consumer Complaints in the Public File? ACBbank
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
It has to be in direct reference to its performance in helping to meet credit needs in its assessment area(s).
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2256236 - 07/01/21 08:32 PM Re: Consumer Complaints in the Public File? ACBbank
Inspector Offline
Gold Star
Joined: Apr 2016
Posts: 283
I would look to the language in the regulation which is not specific to "complaints" but refers to comments. Does the comment provided to the bank relate to the bank's meeting the community credit needs? If so, then it should be included.

(1) All written comments received from the public for the current year and each of the prior two calendar years that specifically relate to the bank's performance in helping to meet community credit needs, and any response to the comments by the bank, if neither the comments nor the responses contain statements that reflect adversely on the good name or reputation of any persons other than the bank or publication of which would violate specific provisions of law;
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Opinions expressed are my own and do not reflect legal advice or the opinions of my employer.

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#2256238 - 07/01/21 08:43 PM Re: Consumer Complaints in the Public File? ACBbank
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
Thank you.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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