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Large Bank CRA Public File

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Question: 
What is required in a large bank CRA public file?
Answer: 

Refer to Section __.43 for public file requirements (Each regulatory agency has their own section number for CRA. The FDIC's is Section 345.43 for instance).

Here's how we address the public file in our Advanced Lending Manual:

All institutions, including small and intermediate small institutions, must maintain a public file and post the required CRA notice. The public file should be updated by April 1 of each year.

Information available to the public
A bank shall maintain a public file that includes the following information:1. All written comments received from the public for the current year and each of the prior two calendar years that specifically relate to the bank’s performance in helping to meet community credit needs, and any response to the comments by the bank, if neither the comments nor the responses contain statements that reflect adversely on the good name or reputation of any persons other than the bank or publication of which would violate specific provisions of law;
2. A copy of the public section of the bank’s most recent CRA Performance Evaluation prepared by the FDIC (Federal Reserve/OCC/OTS). The bank shall place this copy in the public file within 30 business days after its receipt from the FDIC (Federal Reserve/OCC/OTS);
3. A list of the bank’s branches (list all offices including the main bank), their street addresses, and geographies;
4. A list of branches opened or closed by the bank during the current year and each of the prior two calendar years, their street addresses and geographies;
5. A list of services (including hours of operation, available loan and deposit products, and transaction fees) generally offered at the bank’s branches and descriptions of material differences in the availability or cost of services at particular branches, if any. At its option, a bank may include information regarding the availability of alternative systems for delivering retail banking services (e.g., RSFs, RSFs not owned or operated by or exclusively for the bank, banking by telephone or computer, loan production offices, and bank-at-work or bank-by-mail programs);
6. A map of each assessment area showing the boundaries of the area and identifying the geographies contained within the area, either on the map or in a separate list; and
7. Any other information the bank chooses.


Large Banks
A bank shall include in its public file the following information pertaining to the bank and its affiliates, if applicable, for each of the prior two calendar years:
1. If the bank has elected to have one or more categories of its consumer loans considered under the lending test, for each of these categories, the number and amount of loans:
a. To low-, moderate-, middle-, and upper-income individuals.
b. Located in low-, moderate-, middle-, and upper-income census tracts; and
c. Located inside the bank’s assessment area(s) and outside the bank’s assessment area(s); and

2. The bank’s CRA Disclosure Statement. The bank shall place the statement in the public file within three business days of its receipt from the FDIC (Federal Reserve/OCC/OTS).

The CRA Disclosure Statement is the small business, small farm, community development, etc. loan data that the bank can download from the FFIEC’s website. We recommend that you copy this data to a CD-ROM and place it in your public file. If a request is made for the information, it must be printed at that time.


Small and Intermediate Small Banks
A small and intermediate small bank shall include in its public file:
1. The bank’s loan-to-deposit ratio for each quarter of the prior calendar year and, at its option, additional data on its loan-to-deposit ratio; and
2. The information required for large banks, if the bank is elected to be evaluated under the lending, investment, and service tests.


Banks with strategic plans.
A bank that has been approved to be assessed under a strategic plan shall include in its public file a copy of that plan. A bank need not include information submitted to the FDIC (Federal Reserve/OCC/OTS) on a confidential basis in conjunction with the plan.

Banks required to report Home Mortgage Disclosure Act (HMDA) data.
A bank required to report HMDA data shall include in its public file a copy of the HMDA Disclosure Statement provided by the Federal Financial Institutions Examination Council pertaining to the bank for each of the prior two calendar years. In addition, a bank that elected to have the FDIC (Federal Reserve/OCC/OTS) consider the mortgage lending of an affiliate for any of these years shall include in its public file the affiliate’s HMDA Disclosure Statement for those years. The bank shall place the statement(s) in the public file within three business days after receipt.

Banks with less than satisfactory ratings.
A bank that received a less than satisfactory rating during its most recent examination shall include in its public file a description of its current efforts to improve its performance in helping to meet the credit needs of its entire community. The bank shall update the description quarterly.

First published on BankersOnline.com 12/17/07

First published on 12/17/2007

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