Is there anything else that needs to go in the CRA Public Branch File besides the latest Performance Evaluation and list of services? This is a brand new branch, will not open for a couple of weeks. It is in an MSA, so would I need to place our HMDA Disclosure in the file as well?

§228.43 Content and availability of public file.
(2) At each branch:

(i) A copy of the public section of the bank’s most recent CRA Performance Evaluation and a list of services provided by the branch; and

(ii) Within five calendar days of the request, all the information in the public file relating to the assessment area in which the branch is located.

If there are any material differences in the services available or pricing that needs to be noted as well in the branch file.

I section mine into 4 sections, Section one has a fax page with my direct line and information that should be gathered if someone asks for the file or for more CRA information. The person who faxes it signs and dates and I do the same with my noted response (NO ONE has ever asked but dang am I prepared).

Then the PE in section 2

Section 3 is the product information and

Section 4 contains our CRA notice.

Don't you need a description of the assessment area and a nice map

Not in more Don. Andy listed the requirements of the BRANCH file.

The branch file and the main file require different contents. The impressive maps and HMDA files go into the main file.

We finally got smart and placed our Branch file on our Intranet. We still have the main file in paper form, but with 30+ branches and growing, this makes updating the Branch files SO MUCH easier!!!
Leslie

I think that is what I am going to go to as well.

Two questions: 1) if your intranet goes down, what do you do?
2) Have you ever had a request to see the public file?

I have, once, years ago. A church group was told this was a good thing to do. They flipped pages, had no idea what they were looking at and left. I've not heard of a branch request yet.

Back in the day when we had to have a CRA STATEMENT (remember those?), the only people who would call and ask for a copy would be other bankers. Why? Because it was time for them to update THEIR CRA Statement, and everyone plagerized from everyone else. Ahh.. I miss those days sometimes....

I have our branch file in PDF format which has been emailed to all branch managers. They are instructed to print it out and if it's lost, I can always send them another. It beats my having to copy them and send them out. I tried to have it just on their desktop, but then on the managers day off, or they went to lunch, etc..

The only request to see the file is from our competition. ;-)

We have never been asked for the CRA file, the HMDA info or the Part 350 info. But I have public files set up, including instructions to the clerks/secretaries/receptionist should they be asked and I am not available.

Andy,
1. We have all sections of the branch public file in both Word and pdf format. If a client needed a copy, we could get it to them without any problem.
2. To the best of my knowlege, we have had about a half dozen requests since I started in Compliance about 5 years ago, mostly from consumer groups. Of course, our regulators always want to see it, but I'm not counting those requests!

My thought was that having it on your intranet is excellent for delivery, but the branch should either have a printed copy or the file on their local PC for printing (with a backup copy if they only have one printer available).

What do you mean... back in the day? We are a small institution and we have what is called a CRA Statement. Is the CRA officer missing something?

At a minimum, each branch must maintain:
(1) A copy of the public section of the bank's most recent CRA Performance Evaluation and a list of services provided by the branch.

(2) Any negative responses or complaints from customers on bank's performance or customer service, etc. and bank's response

Our CRA officer puts together a CRA Statement that is what I would call a self-assessment. He includes this in the public file.

Quote:

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Our CRA officer puts together a CRA Statement that is what I would call a self-assessment. He includes this in the public file.

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Some institutions do that, however it is not a requirement. Good exercise - yes, but not a requirement.

You need latest performance evaluation and list of services in the branch. Of course, there are additional items required in your head office. If the branch is in an MSA, you need only post a location where the information may be obtained. You do not need to have it in your branch.

I do a full PE on my bank annually, but IMHO I wouldn't put it in the branch or public files. (Some people call the "branch file" the public file, I mean the file in our idividual branches verses the large public maintained in my office that has everything (including those nifty maps Don)

I wouldn't want a client to view my opinion of our standing, verses the actual standing with the regulators. I'd be afraid of confusing someone. My PE (which is a pretty good replica including all apendixes, definations, charts etc) is so close to the OCC's that even bank folks get it confused. Aside from "Internal Examination" on the front page, it's pretty much the same.

I use this for reporting to the board, and to tell me where I stand, as well as provide it to the OCC at PE time, but I wouldn't think of it as a "Public" document that would ever be offered for view. A "CRA Statement" of the same quality or lesser, but still not "official" regulator verbage could cause confusion. I'd think seriously about it's inclusion in the files you allow the public to read.