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#511884 - 03/09/06 08:26 PM complaint file
J2C Offline
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Big Brother knows and that's a...
I am trying to define what exactly goes in the complaint file for CRA purposes. I know they should be related to CRA. So, if someone complains about the overall performance of the bank, should that be included?
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#511885 - 03/10/06 04:34 AM Re: complaint file
Patriot Offline
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Joined: Oct 2005
Posts: 257
First, it's a public file, not necessarily a complaint file. What belongs in a CRA public file is any comment positive or negative from the public (and the bank's response if any) about the bank's efforts to meet the credit needs of its communities, particularly low-to-moderate income persons. This is the heart of CRA. Any other kind of complaint has no place in the file in my opinion.


Sec. 228.43 Content and availability of 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" [emphasis added]
Last edited by IronGuy; 03/10/06 12:59 PM.
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#511886 - 03/10/06 01:24 PM Re: complaint file
J2C Offline
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Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
Thanks. I know it is the public file. I guess I should have explained that we have a complaint file within the public file. sheeze.

Thanks for quoting the reg too, already knew that. I was looking for more specifics though. What I think should go isn't exactly what others think should go.
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#511887 - 03/10/06 02:20 PM Re: complaint file
Lestie G Offline

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Joined: May 2002
Posts: 3,606
Near the Land of Enchantment
I think what Ironguy was trying to say is that the file should contain any letters of praise related to your bank's CRA performance as well as any complaints.

As far as what types of complaints - I suppose it is kind of subjective. I've always tried to think of it from a CRA examiner's viewpoint. Is this letter something that the examiner would consider in my CRA exam? If the letter is complaining that the bank didn't make it's ROA goals - I don't think that would make it in the file.

Hopefully that helps. It is tough sometimes to decide. Maybe a small committee could make those calls - armed with the regulation and some input from your regulator of course!
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#511888 - 03/10/06 02:29 PM Re: complaint file
J2C Offline
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Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
Thanks Lestie, that helps!
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