My guess is 99% of us never have comments that need to be included in the public file. The new regulations require we update the comments section of the public file quarterly. I'm looking for some creative wording to use to make it clear there have been no comments but to avoid having to actually list each quarter.

I was thing of something like: "There were no public comments in 2022 & 2023, nor have them been any thus far in 2024."

Of course I would change it and list any if one actually came in. But since I have a greater chance of winning the lottery, I'm thinking this will work for 2024 and the quarterly updates.
Thoughts?

Why not say that you have received no public comments in the current calendar year nor in the last two calendar years? Then you never have to touch it.

Thanks Randy. I like that.

Randy: it's my understanding we now have to update comments quarterly, so I was thinking just referencing the "prior year" didn't really cover a quarterly update. but I might be over thinking it.

You have to add any comments that you receive quarterly. If you have no comments, there is nothing to update. There is no reason that you have to go in every quarter and say you still have no comments.

I noticed a bank entered public comments from customers who were unhappy when a branch closed or consolidated. Are these types of comments required in the Public File??

(a) Information available to the public. A bank shall maintain a public file that includes the following information:

(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;

If they felt that closing the branch impacted the bank meeting the community credit needs, you bet.