I'm trying to make sure I understand exactly what comments need to be included in our CRA public file. I get that thank you notes go into the supplemental file with our donations and service hours records. I don't think we've ever recieved a letter that specifically referred to CRA.

We have recently implemented a Comment Card program, and we have received lots and lots of comments (mostly good, a few not so good), but I'm having trouble determining which of these should perhaps be included in our public file--if any. Many many of them are just "you're great, we love having a small bank in the community", or "thanks for taking the time with an elderly person like me", but I don't think that's exactly what the examiners are looking for. (Though if it is, that file is about to get huge!)

I've searched the threads and looked elsewhere online, but so far cannot find a actual example of what a CRA comment might look like if it doesn't specifically reference the Act. Am I being completely dense here?

The comments that are required relate to meeting credit needs in your community/assessment area and the bank's response...so if there were letters saying you don't make enough small business or home mortgage or consumer loans those would go or about fair lending (or that said you were fantastic, the reg doesn't say just include bad comments).

These should be edited to meet this statement: 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;


The bank can include anything it wants in the public file so anything else is up to you.

I've never kept general comments in the public file. I interpret the regulation to include only comments received about our performance in meeting the lending and general banking needs of our local communities as they relate to CRA compliance.

In my career, I think I have had only 3 comments included in the file. Two of the comments were asking to receive copies of our public file. The 3rd comment actually remarked on our CRA ativity. I included the bank's response to that comment in the file as well.