I have been brainstorming with my coworkers an alternative way to publish our CRA Public File. (I work for a bank that is examined under the large banking CRA tests.) I update our Public File quarterly to ensure that the file is up to date. Our Public File is currently in three ring binder format and there are 34 copies of it (one in each branch). I know the intent of the Public File is to have information available for the customer to view and or take home.

One of the alternative ways of publishing the Public File we came up with was to publish it to our company Intranet site. If and when a customer comes in and askes for a copy, the branch personnel could print the customer a copy. What do you all think about this alternative?? Do you think it will fly with the examiners? How are others updating and publishing their Public Files?
Thanks MHughes

I have thought of the same thing. As frequently as the PF is requested, in my mind this would work. The problem is, technical difficulties.

Why not publish it in this manner and let the branches download it to a hard drive. They could print it or just keep it on one (or more) computers. The customer could look at it there, receive it electronically or get a paper copy.

BB allows that the "copy" may be either on paper or in another form acceptable to the person making the request. Look to 228.43.

I only see snags in getting the HMDA reports in there and the prior customer comments. PDF would solve those easily. The HMDA could also be ported into a spreadsheet format.

I think it is a great idea.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

Wow - that seems like a lot of work.

The Regulation only requires the main Public File to be kept at your main office (if you are an interstate bank - then a copy in at least one branch in each state.)

At your branches you only need to keep a copy of the Public Evaluation and a list of services provided by the Bank.

You only need to make the Public File available to someone within 5 calendar days of their request for it.

At least this is what section 345.43 of the FDIC Rules & Regs states.

We used to keep a copy of the Main Public file at each branch - but the problem is maintaining all of those files in a current and complete fashion. It's akin to trying to herd cats (not a recommended activity....)

I too used to keep a full copy at each branch. That did grow to be a monster and I cut it down to necessary sections only. But most everything is on my PC already.

If I could just add a few easy elements and make the entire PF available in e-form, it would be simpler because instead of breaking down and delivering each branches copy, I'd do my master file and deliver it.

The ease of implementing this procedure will depend on how your files are established and how many non-electronic files they are composed of, such as maps, brochures, HMDA reports, etc.

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Andy Zavoina
Opinions stated are not necessarily that of my employer.

I have actually accomplished the publication of the CRA Public File on the Intranet of a $1.2 billion bank with 33 branches in two states. It wasn't hard at all and tremendously cut down on the update times. We used a combination of HTML and PDF formats. Some added benefits included the ability to have the complete public file available in all branch offices and the ability to have maps linked to census tracts, including street level maps for low- and mod- census tracts.

We used our mapping program, Tactician, and copied screen shots of maps and converted them to GIF files. For written comments about our performance and our responses, we scanned the letters into PDF files. Same thing for HMDA and CRA disclosure data. CRA Performance Analyses were already available in PDF form from the FDIC website, so we just downloaded a copy for our server. Other files we created in HTML. It was a very slick product and the FDIC examiners at our last CRA exam loved it.

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Opinions expressed are my own, and do not necessarily reflect those of my employer.