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#336956 - 03/22/05 04:08 PM public file checklist
Anonymous
Unregistered

Can someone provide me with a listing of all that is required to be in the public file. We are a bank which is going to be examined under "large bank" criteria for the first time in May 2005 and have not had a CRA exam since 1999. I want to make sure the public file is complete and up to date as of April 1st. Thanks for any assistance--checklists, web links, etc. Steve

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CRA
#336957 - 03/22/05 05:01 PM Re: public file checklist
Rie A Offline
Platinum Poster
Rie A
Joined: Mar 2004
Posts: 829
Maryland
Go here:
http://www.fdic.gov/regulations/laws/rules/2000-6500.html#2000part345.43
Then go down to:
§ 345.43 Content and availability of public file.
Basically:
1) Any written comments received from the public ....
2) A copy of the public section of the most recent CRA Performance Evaluation.....
3) A list of the bank's branches, their street addresses and geographies served.
4) A list of the branches the bank opened or closed ....
5) A list of serviced generally offered at the banks branches.....
6) A map of each assessment area...
7) Except for small banks....., if applicable, for each of the prior two calendar years:
. i. If the bank has elected to have one or more categories of consumer loans considered under the lending test......
. ii. The bank's CRA Disclosure Statement.....
8) If the bank is required to report HMDA data, a copy of its HMDA Disclosure Statement ......
9) small banks
10) The banks strategic plan, if the bank has been approved....
11) For any bank that received a less than satisfactory rating.....
12) Any other information the bank chooses.
_________________________
God made the world in only 7 days... but he didn't have any paperwork.

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#336958 - 03/22/05 05:31 PM Re: public file checklist
Anonymous
Unregistered

this is good BUT we are OCC regulated any link to an OCC publication????

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#336959 - 03/22/05 06:02 PM Re: public file checklist
Angel Eyes Offline
Power Poster
Angel Eyes
Joined: May 2001
Posts: 4,599
I didn't go through it word by word but I believe the public file content is the same.

Here is the OCC link.

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#336960 - 03/22/05 06:05 PM Re: public file checklist
Rie A Offline
Platinum Poster
Rie A
Joined: Mar 2004
Posts: 829
Maryland
The regulation is currently the same for everyone.

Here is a link to OCC
http://www.occ.treas.gov/fr/cfrparts/12CFR25.htm
_________________________
God made the world in only 7 days... but he didn't have any paperwork.

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#336961 - 03/22/05 06:10 PM Re: public file checklist
Rie A Offline
Platinum Poster
Rie A
Joined: Mar 2004
Posts: 829
Maryland
Sorry Jennifer, I must have been attaching my link when you posted, I did not see it before I attached mine.

Also, for OCC it is §25.43 instead of §345.43
_________________________
God made the world in only 7 days... but he didn't have any paperwork.

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#336962 - 03/22/05 06:34 PM Re: public file checklist
Anonymous
Unregistered

Thanks for the links.......I think I am all set...Steve

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#336963 - 03/22/05 08:15 PM Re: public file checklist
Len S Offline
Diamond Poster
Joined: Oct 2004
Posts: 2,150
Connecticut
The public file should contain a list of services and charges and any difference in services or cost between branches. Furthermore, the file should be updated at least annually as of April 1. It is a good idea (as part of "process" that is now emphasized in the new exam procedures) to maintain a log showing that the CRA officer reviewed the file as of ____ and showing that the documentation is current and complete. This is not explicitly required in the regulations, but with the new emphasis on controls and procedures examiners will be looking to see what internal processes are implemented to assure the collection, compilation, maintenance and reporting of all required information. Furthermore, banks will be expected to have some kind of documented self-assessment process that shows they are staying on top of their CRA responsibilities.
_________________________
CRA Exam Preparation, CRA Performance Evaluations, Key Performance Benchmarks, & maps

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