We call our public file are CRA Policy as well. Regardless of what we call it, should the public file be presented and approved by the board annually?
Posted By: AEA
Re: CRA Policy - 07/27/06 10:54 PM
The only requirement is that the institution have a public file. It is a good idea to share with the Board on a periodic basis the contents of the public file.
Posted By: Andy_Z
Re: CRA Policy - 07/28/06 02:46 AM
Your policy and public file should be separate and I would try not to mix them as being one in the same, regardless of what you call it.
Policies are road maps, directions from the board. (FYI this has been discussed may times and you can find several opinions in different threads.) By having them annually reaffirm the policies, they affirm that is still the direction they want to go. What your direction is in your policy, and any discussion on investments, housing needs assessments etc. is not public information. Do you really want to give that to your competition?
If you wanted to pick a time to report the Public File to the board, I would +/- April 1 as that is the required update date in the Reg.
Personally, the board was routinely updated about market areas, loan and deposit numbers, complaints and comments, so they already had everything that was in the Public File, just not tied together with a ribbon.