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.
Last edited by IronGuy; 03/10/06 12:59 PM.
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]