Solving Common Violations

Reg BB: Community Reinvestment Act

_.42(a): Loan information collected

• Collecting information for reporting on loans other than mortgages is a chronic problem. It is a particular problem for business loans.
• Use a CRA information collection form (this can be part of a multi-purpose form) to collect the information needed for CRA reporting. Collect information on loan location, loan type, loan purpose and loan amount.

_.42(b): Loan information reported

• Use the loan information sheets as source documents for data entry and reporting. The best place to get the information is from the lender who originated the loan.

_.43: Public file

• This should be so easy. Check periodically to be sure the file is accurate, up-to-date, and complete.
• Check every location that should have a CRA file to be sure the file is there and is complete.

_.44: Public Notice

• Get the poster language right and put the posters in the branch lobbies!
• Use a branch audit schedule to check the CRA lobby posters.

Previously highlighted Common Violations:
Reg C- Solving Common Violations
Reg E: Electronic Funds Transfers
Reg H: Flood Hazard Insurance
Reg X: RESPA
Reg Z: Truth in Lending
Copyright © 2001 Compliance Action. Originally appeared in Compliance Action, Vol. 6, No. 6, 6/01