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.
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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