We place a full copy of the CRA public file into all offices (main or branch)which includes all information on both assessment areas. Is it acceptable to put the CRA main notice into a branch? If so, is there a regulatory site for that or has anyone had experience with regulators on this?

Technically, your branches (other than the designated branch office in each state other than the main office) would be out of compliance with the requirement set forth in the Regulation:

Sec. 228.44 Public notice by banks.

A bank shall provide in the public lobby of its main office and each of its branches the appropriate public notice set forth in Appendix B of this part. Only a branch of a bank having more than one assessment area shall include the bracketed material in the notice for branch offices. Only a bank that is an affiliate of a holding company shall include the next to the last sentence of the notices. A bank shall include the last sentence of the notices only if it is an affiliate of a holding company that is not prevented by statute from acquiring additional banks.


Appendix B to Part 228--CRA Notice

(a) Notice for main offices and, if an interstate bank, one branch office in each state.

(b) Notice for branch offices.

We keep our public file electronically and it contains both the branch and main office notices. The entire file would be printed out in one shot and would include both notices.

We had an exam last year and there was no mention of it.

The examiners did not notice that the lobby notice was not posted in the lobby of the main office or branch offices?