Good morning - I'm curious at to how other Banks have handled the update to their CRA notice after changing Prudential Regulators. My Bank has moved from the FDIC to the Fed Reserve Bank. With that being said, the opening bullet point of the CRA notice provides a reference to the 'most recent CRA Performance Evaluation, which is still the FDIC.

Later in the notice, there is a reference that 'At least 30 days before the beginning of each quarter, the "prudential regulator" publishes a list of the banks that are scheduled for CRA examination by the 'prudential regulator' in that quarter.' For this part, we feel that it needs to be revised from FDIC to FRB at as swiftly as possible.

How did your Bank handle this? Did you roll out a hybrid notice that references the previous prudential regulator that last performed a CRA Performance Evaluation, which in our case is the FDIC, and then update the rest of the notice to display Federal Reserve Bank information. If you take this route, you would have to go revise the notice again once the FRB has performed its first CRA Performance Evaluation.

Or, did you leave the CRA notice unchanged and wait until your new prudential regulator had performed a CRA Performance Evaluation, so that you could roll it out entirely with references to the new prudential regulator.


Thanks!

This is a great question, Comply2023. While I don't recall what I have seen other banks do in this situation, I would reach out to your (new) regulator and ask them how they want you to handle it. I would think your proposed method appears sound, but the Fed's opinion is really all that matters as they are the ones who will be examining you.

Adam - I appreciate the response. Sadly we have been unable to obtain a response directly from the Fed.

I will report back once we make a decision here, so that others who run into this in the future can be aware.