How is everyone complying with the requirement to include a list of services (including available loan and deposit products and TRANSACTION FEES) in thier CRA Public File?

Dolly Nugent
VP/Compliance & CRA Officer
Citizens Business Bank

I do not list the fees, but suggest they obtain a copy of the current Deposit Account Agreement from New Accounts. Otherwise, yes I list services offered.

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Al Miller, CRCM
Fremont Bank (CA)
(510) 790-5825
(510) 505-5211 FAX

Opinions expressed are my own and not necessarily shared by my employer.

Al,

You have the magic answer that I was looking for. I have been including our Schedule of Fees and Charges, but now I will do the same.

Dolly

I have always read the Public File content requirements to mean that the fees had to be disclosed in the Public File.

I'm not certain a reference to obtain additional documentation would be acceptable.

I believe Al just went through a CRA exam. Was this specifically approved? I'd also look to any comments from AR.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

We include a copy of our most recent products and services brochures along with a copy of the fee schedules.

345.43(a)(5) A list of services (including hours of operation, available loan and deposit products, and transaction fees) generally offered at the bank's branches and descriptions of material differences in the availability or cost of services at particular branches, if any.

Our practice is to place the most current "Summary of Fees" brochure in the file to comply with this requirement.

No, Andy, it was not specifically approved, nor was it "dinged." We have 20 copies of the current version of our Public File (one in each branch) and the only copy that has been looked at in the past 5 years is mine. It has been looked at exactly twice. Both times by FDIC examiners.

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Al Miller, CRCM
Fremont Bank (CA)
(510) 790-5825
(510) 505-5211 FAX

Opinions expressed are my own and not necessarily shared by my employer.

My recommendation would be to drop the fees and services list into the CRA public file. Then there are no questions. Granted, the information is readily available by asking, but why make consumers take this step -- and get irritated with you?

I also use our New Account inquiry brochure booklet to provide the information. The booklet is smaller then regualr paper--so I just photo copy it on regular 81/2x10 paper to make it fit in a 3-ring binder.

I think most examiners wouldn't make a big deal out of this issue. While the reg says to include the transaction fees, I don't see a reference to where they may obtain the fee schedule being significant deviation from the intent of the reg here. The intent is to give the consumer ready access to the fee structure. As long as some reasonable means is employed to achieve that, I don't see this elevating beyond a discussion with you. I doubt the violation would even make into the report of examination. AR.

Here's an idea I suggested to my banks regarding the CRA public file. CRA public files are a royal pain. Keeping them up to date, making sure consumers who request to see the file get the most up-to-date version (of course, almost no-one ever asks to see it)is not an easy control task. Two of the banks I work for have put the CRA Public File on their Intranet complete with maps etc. If anyone inquires, it can be printed very quickly. It also makes updating easy.
Just food for thought.