Just a friendly reminder that your Community Reinvestment Act (CRA) Public File must be updated by April 1, 2020. This includes the public files kept at both the main office and each branch location (if applicable). For a full listing of what you should include in your CRA Public File, please refer to §345.43 (FDIC), §25.43 (OCC), or §228.43 (Federal Reserve).
The following items are often overlooked when updating your CRA Public File:
- Any branches opened or closed in the current year and each of the prior two calendar years (including their street addresses and geographies);
- Current services offered;
- Up-to-date transaction fees; and,
- For small and intermediate-small financial institutions only, an up-to-date loan-to-deposit ratio for each quarter of the prior calendar year.
While we’re on the topic of CRA, you may remember our recent blog about the OCC and FDIC’s proposal to modernize the CRA requirements. The comment period was set to end on March 9, 2020; however, it has been extended until April 8, 2020. We encourage you to review the proposal and submit your feedback as this could greatly affect some financial institutions.
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