Fees for accounts in CRA branches

Posted By: corporate audit

Fees for accounts in CRA branches - 09/05/18 12:32 PM

During a recent audit it was found that branches in a CRA area are charging lower OD and NSF fees than branches in a non-CRA area. Is there any problem with that?

Thanks in advance.
Posted By: rlcarey

Re: Fees for accounts in CRA branches - 09/05/18 12:36 PM

Considering ODs are credit under Regulation B - charging customers different amounts might represent a fair lending issue. I am not really sure what a CRA area might be however.
Posted By: corporate audit

Re: Fees for accounts in CRA branches - 09/05/18 02:54 PM

The CRA area mentioned means that branch is located in a low income area.
Posted By: Princess Romeo

Re: Fees for accounts in CRA branches - 09/11/18 08:20 PM

Is the lower fee charge in LMI branches a conscience effort by the bank to provide lower costs services to LMI residents? I would recommend a legal review to determine if this should be done under a "special purpose credit program" since the benefit is in LMI areas and likely to be higher minority areas. If you are a Large Bank, you can then highlight it under your Services test.
Posted By: mrogersfib

Re: Fees for accounts in CRA branches - 10/22/18 06:39 PM

Agree with Princess that this would present favorably under CRA's service test. Such a behavior would not be a critical deciding factor in your exam rating, but would rather a qualitative factor for examiners to consider when evaluating the banks responsiveness to its customers.