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#1142537 - 03/09/09 11:10 PM Public Files
Busy Bee, CRCM Offline
Diamond Poster
Joined: Feb 2004
Posts: 1,089
PacificNW
If we closed a Loan Production Office, does that information have to be included in our CRA Branch/Public File? I believe, after reading the reg, that it is only closed branches and not LPOs.

Thanks!

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#1142540 - 03/09/09 11:29 PM Re: Public Files Busy Bee, CRCM
Mrs. Rizzo Offline
10K Club
Mrs. Rizzo
Joined: Mar 2006
Posts: 10,392
Curled up by the fire...
I don't consider an LPO to be a branch. Unless, the LPO had the capability of taking deposits???
I don't think you would need to include this one.
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#1142541 - 03/09/09 11:37 PM Re: Public Files Mrs. Rizzo
Busy Bee, CRCM Offline
Diamond Poster
Joined: Feb 2004
Posts: 1,089
PacificNW
Nope, no deposit-taking. That's what I thought too, but I needed confirmation that I was on the right page!

Thanks, Riz!

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#1142575 - 03/10/09 11:57 AM Re: Public Files Busy Bee, CRCM
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,388
Galveston, TX
Accepting deposits may or may not be the trigger. From the CRA Q&A:

§ll.12(f)–2: Are loan production offices (LPOs) branches for purposes of the CRA?

LPOs and other offices are not ‘‘branches’’ unless they are authorized as branches of the institution through the regulatory approval process of the institution’s supervisory agency.
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