Two questions:

1) Do we need to have the ECOA notice in each lenders office or is just the lobby sufficient. I have it in my head that each office needs it but can't find it anywhere specific.

2) If we have a public file at each branch that is the same as the main office file, can we get away with posting the CRA notice for the main office instead of the branch office (for each of our brances)?

You only need the 'public file' in the main office. Each branch will have the branch notice and also maintain a copy of the Public Evaluation from your most recent CRA exam and a copy of your services.

With the above being said, if your assessment area has two separate MSA's or is on more than one state, you will need a public file at one location in each MSA or state.

For the ECOA notice - one in the lobby is sufficient. Remember, this needs to be visible to anyone who comes in to apply for a loan. I worked for a bank that was written up by the FDIC because the sign was 'around the corner' and not everyone would see it.

Thanks on the Equal Lending.

The bank I'm at actually has the full public file at each office (even though not required) but they have the main office disclosure posted, not the branch notice.

I think this is okay, since the branch notice basically says we can get this to you, but in this case all of the information is already at each office.

Any thoughts on the notice, whether or not it makes sense?

Skittles, I'm not aware of anything that says you've got to have the main public file located in each separate MSA. I am aware of the requirement to have it available in at least one office in each additional state where the bank is located.

I would still use the branch notice as nothing in there would be incorrect by virtue of having the whole public file available at each branch. We have our public file available on our intranet, so it is completely available in each branch, but we still use the branch notice in our branch offices.

Magic - thanks for the correction. I know that when I was a consultant this is what we told our clients. Now I know better.