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#506699 - 03/01/06 07:00 PM Public File Question
J2C Offline
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We are thinking about putting our public file (with the exception of our main office) on our intranet. Would this be a problem?

Also, if someone does go into one of the branches and requests this information, and it is on the intranet, we would obviously print it out to show them the info. Is this information that a customer/consumer can take out of the branch?

Sorry if these seem silly- new to this process.
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#506700 - 03/01/06 08:13 PM Re: Public File Question
CubDave Offline
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JFTB - yes - I keep my branch files on our Intranet and it certainly could be printed and given to customer - it is just a list of services, locations, etc, plus the PE.

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#506701 - 03/01/06 08:25 PM Re: Public File Question
Don_Narup Offline

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Las Vegas Nevada
The following needs to be provided within 5 days of a request to provide. It's simpler to just put it in the Public File. A Map of the assessment area showing branch office lcations

Copies of all written comments received that specifically relate to CRA performance in the assessment area, and any responses made to those comments.

Information about branches in the assessment area; and a list of services provided at those locations;

Data on lending performance in the assessment area;
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#506702 - 03/01/06 08:30 PM Re: Public File Question
J2C Offline
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Thanks. Most of that info (with exception of the complaints) would be located on the intranet. The main file will be in the main office, in hard copy with all of the other information.

I guess my next question should be this- we are a bank that only has offices in one county (and plan on staying that way). Are we required to have a PF in each location even though all of our locations are located in one county?

Currently, we have a PF without the complaint file and the HMDA data in all locations. The main office has everything else. We were just looking to streamline the process for the other locations.

Thoughts?
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#506703 - 03/01/06 09:19 PM Re: Public File Question
CubDave Offline
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Quote:

The following needs to be provided within 5 days of a request to provide. It's simpler to just put it in the Public File. A Map of the assessment area showing branch office lcations

Copies of all written comments received that specifically relate to CRA performance in the assessment area, and any responses made to those comments.

Information about branches in the assessment area; and a list of services provided at those locations;

Data on lending performance in the assessment area;


Don, my research says that branch files need only include the Public section from exam,list of Services, and listing of facilities within the assessment area, including information such as hours of service, tract number, and geographic areas served.

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#506704 - 03/01/06 10:11 PM Re: Public File Question
Don_Narup Offline

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Look at page 38 of CRA Getting it Right Guide. "Content and Availability of Public File"

There is more than whatI posted

a list of branches opened or closed by the bank during the
current year and each of the prior two calendar years, their street addresses, and geographies;

if the bank has elected to have one or more categories of
its consumer loans considered under the lending test, for each of these categories, the number and amount of loans—
(A) to low-, moderate-,middle-, and upper-income individuals;
(B) located in low-, moderate-, middle-, and upper-income census tracts; and
(C) located inside the bank’s assessment area(s)
and outside the bank’s assessment area(s); and

(ii) the bank’s CRA disclosure statement. The bank shall
place the statement in the public file within three business days of its receipt from the Board

Banks required to report Home Mortgage Disclosure Act (HMDA) data. A bank required to report home mortgage loan data pursuant to part 203 of this chapter shall include in its public file a copy of the HMDA disclosure statement provided by the Federal Financial Institutions Examination Council pertaining to the bank for each of the prior two
calendar years. In addition, a bank that elected to have the Board consider the mortgage lending of an affiliate for any of these years shall include in its public file the affiliate’s HMDA disclosure statement for those years. The bank shall place the statement(s) in the public file
within three business days afterits receipt.

Small banks.
A small bank or a bank that was a small bank during the prior calendar year shall include in its public file—
(i) the bank’s loan-to-deposit ratio for each quarter of the prior calendar year and, at its option, additional data on its loan-to-deposit ratio; and

(ii) the information required for other banks by paragraph(b)(1) of this section, if the bank has elected to be evaluated under the lending, investment, and service tests.
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#506705 - 03/01/06 10:23 PM Re: Public File Question
CubDave Offline
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That is all true for the full file at your Main location - there are no such requirements to maintain all that information at your other branches within the State.

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#506706 - 03/01/06 10:24 PM Re: Public File Question
J2C Offline
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I think CD is right....I don't think all of that needs to be in each location. But, I am new to this so don't take my word on that.

(c) Location of public information. A
bank shall make available to the
public for inspection upon request
and at no cost the information
required in this section as follows:
(1) at the main office and, if an
interstate bank, at one branch
office in each state, all information
in the public file; and
(2) at each branch:
(i) a copy of the public section
of the bank’s most recent CRA
performance evaluation and a
list of services provided by the
branch; and
(ii) within five calendar days of
the request, all the information
in the public file relating to the
assessment area in which the
branch is located.
(d) Copies. Upon request, a bank
shall provide copies, either on paper
or in another form acceptable to the
person making the request, of the
information in its public file. The
bank may charge a reasonable fee
not to exceed the cost of copying
and mailing (if applicable).
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#506707 - 03/01/06 10:38 PM Re: Public File Question
MB Guy Offline
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Posts: 10,124
Way, way south.
Any thoughts as to where to go for the maps in electronic format to put out there on the intranet?
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#506708 - 03/01/06 11:39 PM Re: Public File Question
Don_Narup Offline

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Las Vegas Nevada
I can make them
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#506709 - 03/01/06 11:50 PM Re: Public File Question
Don_Narup Offline

Power Poster
Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
The question was:

"if someone does go into one of the branches and requests this information, and it is on the intranet, we would obviously print it out to show them the info. Is this information that a customer/consumer can take out of the branch?"

If the "Public File" is on the intranet available at each branch wouldn't it be the whole file?

IMO put the full Public Fle up and available. The bank is going to have to provide the full file within 5 days of the request anyway.

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#506710 - 03/02/06 01:43 PM Re: Public File Question
J2C Offline
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Posts: 1,475
Big Brother knows and that's a...
Don:

I see what you are saying now. In this instance all of our locations are within the same county, so I don't forsee this as a problem (getting the full file to someone that requests it within 5 days).

Thanks for your input.
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#506711 - 03/02/06 02:35 PM Re: Public File Question
CubDave Offline
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Joined: Oct 2005
Posts: 1,562
I thought that might be what Don was getting at (since he is Mr. CRA). In our case, we have 6 branches in a fairly tight geographic area. To scan all the stuff in the Public file to post on the Intranet just isn't a priority and if we did get a request (which we never have), we would just copy within 5 days no problem. The reason I put the abbreviated stuff (Branch file) on the Intranet was because when staff moves around, you struggle with where the branch file was kept and was it properly maintained. Having the branch file on the Intranet allows me to make sure it is always current.

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#506712 - 03/02/06 04:15 PM Re: Public File Question
Don_Narup Offline

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Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
It's a lot of maintenance, and what purpoase it serves I'm not sure. Updateing it is another task that has to be done once a year. In my 30 years of banking I had one person ask to see the Public File, and it turned out to be a person employed at a competitor institution, that wanted to use ours as a gouge to make theirs.

Just for kicks I asked my local bank about their public file (actually trying to solicite them for a mapping job).Not only did they not know where it was, they didn't know what it was.
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#506713 - 03/02/06 04:43 PM Re: Public File Question
RFitzpatrick Offline
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RFitzpatrick
Joined: Apr 2002
Posts: 424
Pacific NW
Under Don's listing, for small banks, you must include loan to deposit ratio info. For us former large bank, now ISB's, is this something that needs to be added now? What if I still reported data to maintain the large-bank option, but if we decide to go ISB should we have that in there?
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#506714 - 03/02/06 05:23 PM Re: Public File Question
Don_Narup Offline

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Posts: 3,708
Las Vegas Nevada
I haven't seen any Public Fle criteria for ISB's. However examining the banks Loan to Deposit Ratio is part of the ISB exam.

My guess is it would not be required to be in the Public file of an ISB as the criteria says its a "Small Bank" requirement
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#506715 - 03/02/06 07:02 PM Re: Public File Question
MarieR Offline
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Joined: Nov 2005
Posts: 614
But isn't an ISB just a subdivision of small bank and thus wouldn't the same requirements apply?
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#506716 - 03/02/06 07:14 PM Re: Public File Question
Rie A Offline
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Rie A
Joined: Mar 2004
Posts: 829
Maryland
I was reading that ISBs were sub-sets of Small Banks and therefore would have to put the ratio in our public file.

I am pretty sure we are going to stay with the large bank status but figured it is such an easy thing to put in the file, until I am sure one way or the other, I would just put it in the file.
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#506717 - 03/02/06 08:43 PM Re: Public File Question
Don_Narup Offline

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Posts: 3,708
Las Vegas Nevada
Quote:

But isn't an ISB just a subdivision of a small bank and thus wouldn't the same requirements apply?




An ISB is Intermediate Small Bank which is one step up from a Small Bank and one below a Large Bank.
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#506718 - 03/02/06 10:19 PM Re: Public File Question
kmg Offline
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kmg
Joined: Dec 2002
Posts: 124
Wisconsin
I attended an OCC teleconference and specifically asked what direction an ISB should use for public file disclosure. I was told an ISB should follow the rules for a small bank. But remember, that if you are a HMDA reporter, you need to include HMDA data regardless of your "CRA size."

kmg
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