I believe your interpretation is correct. They cannot stop you from closing the branch. They can, however, especially if the branch is in a low- or moderate-income census tract, muddy the waters somewhat. Consumer groups are entitled to write to your regulator to request a meeting be held to get you to explain how you will continue to meet your CRA obligations with the branch closure. Ultimately, it could potentially hurt your CRA rating, but it can't be stopped by the regulators nor the customers.
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Jim Bedsole, CRCM, CBA, CFSA, CAFP
My posts - my opinions