I noticed several threads that briefly mention the Sunshine Act. These threads are primarily in the CRA forum. I am unfamilar with the Sunshine Act - based on the little I picked up from these threads, does it have something to do with Management and Board oversight?

I would appreciate any guidance or link so I can learn more.

Thanks

Reporting agreements (effective April 1, 2001)
1. Any written contract, arrangement or understanding made to a person or non-governmental entity, pursuant to fulfillment of CRA must be reported if the bank provides more than $10,000 in cash, grants or other consideration or more than $50,000 in aggregate principal loan amounts in a calendar year. This must be reported to the bank’s regulatory agency within 30 days after entering into the agreement.

2. Individual mortgage loans, contracts, or commitments for loans are exempt from the reporting requirements if the rates are not substantially below market rates and if the purpose is not for re-lending to another party.

3. A copy of the agreement is to be placed in the bank’s CRA public file.

Thanks Lois.

How is this reported to the regulatory agency? Is there a specific form?

Let me pose a situation - A financial institution gifts $12,000.00 to a private college or university with the purpose of the monies is to provide students of low-to-moderate income with scholorships, would this be reportable?

Do you have a link so I may read further?

Anon, no need to report that. In a nutshell, if the University twisted your arm by mentioning in writing that you needed to do this because of poor CRA activity, then it would be reportable. It's basically to protect us from bribing community agencies, and the agencies from blackmale to us

You might do a BOL Search on Sunshine as I know I for one have done extensive posts on the subject. In the mean time, here's a quick couple of links: (The second is best)

http://www.federalreserve.gov/boarddocs/press/boardacts/2001/20010322/attachment.pdf

http://www.occ.treas.gov/ftp/bulletin/2001-50a.pdf

BTW - has any bank ever been dinged for not reporting something under the Sunshine Act?

I'm not sure if that would be public Bonnie. I do know they did look at my file to see if I was aware and in compliance during my last exam.