April brings many special events – baseball’s home opener, spring showers to bring May flowers, and let’s not forget the CRA Public File update.
Section 43(e) of your bank’s CRA regulation states the Public File should be current as of April 1st each year. To help you, we’ve included some handy information to ensure your Public File is updated. We recommend making sure any dated material has a current date and the information is current. Public file information that needs updating includes:
- Products/services,
- Fees (deposits and loans),
- Loan-to-Deposit ratios (if applicable),
- Branch listings, especially if there have been any branch openings/closings (including geographies),
- Maps if included,
- Public comments,
- Hours of operation, and
- Census tract changes.
It’s important to note there have been significant census tract changes in the past few years, particularly in 2022, so a refresh of the census tract listing in your public file might be in order. TCA advised of these changes in a prior article.
Also, this is the perfect time to do your Public File monitoring under your CMS program and File Spring Cleaning. You can use the charts on the following pages to see what should be in the File. Be sure to use the correct chart for your size bank!
And don’t forget – your CRA Public File does not have to be on paper. It can be retained and made available electronically, such as through email or on your bank’s website; however, it would have to be printed on request or be provided electronically if requested in that format. This could be particularly handy for your institution’s CRA reports (if applicable) and census tract listing which can be quite lengthy.
TCA is A Better Way for great help and great tools to keep in compliance. Contact us today at [email protected] or by phone at (800) 934-7347.
| Required Element | Large Bank | YES | NO | N/A | COMMENTS |
| All credit-related comments and responses for the current year plus two prior years (if any) | Required | ||||
| Most recent CRA Performance Evaluation | Required | ||||
| Branch addresses and geographies served | Required | ||||
| Branch openings/closings for the current year plus two prior years | Required | ||||
| List of lending and deposit products | Required | ||||
| Hours of operation | Required | ||||
| Transaction fees | Required | ||||
| Alternative delivery services | Optional | ||||
| Assessment area map(s) | Required | ||||
| Identification of geographies | Required | ||||
| Quarterly loan-to-deposit ratio | N/A | ||||
| HMDA written notice to obtain data from CFPB (if HMDA reporter) | Required | ||||
| Consumer loan data | Optional | ||||
| CRA Disclosure Statement | Required | ||||
| Strategic Plan (if applicable) | Required | ||||
| Other Information | Optional |
| Required Element | Small Bank/ISB | YES | NO | N/A | COMMENTS |
| All credit-related comments and responses for the current year plus two prior years (if any) | Required | ||||
| Most recent CRA Performance Evaluation | Required | ||||
| Branch addresses and geographies served | Required | ||||
| Branch openings/closings for the current year plus two prior years | Required | ||||
| List of lending and deposit products | Required | ||||
| Hours of operation | Required | ||||
| Transaction fees | Required | ||||
| Alternative delivery services | Optional | ||||
| Assessment area map(s) | Required | ||||
| Identification of geographies | Required | ||||
| Quarterly loan-to-deposit ratio | Required | ||||
| HMDA written notice to obtain data from CFPB (if HMDA reporter) | Required | ||||
| Consumer loan data | Optional | ||||
| CRA Disclosure Statement (if CRA reporter) | Optional | ||||
| Strategic Plan (if applicable) | Required | ||||
| Other Information | Optional |
| Required Element | Branch Office | YES | NO | N/A | COMMENTS |
| All credit-related comments and responses for the current year plus two prior years (if any) | ** | ||||
| Most recent CRA Performance Evaluation | Required | ||||
| Branch addresses and geographies served | ** | ||||
| Branch openings/closings for the current year plus two prior years | ** | ||||
| List of lending and deposit products | Required | ||||
| Hours of operation | ** | ||||
| Transaction fees | ** | ||||
| Alternative delivery services | Optional | ||||
| Assessment area map(s) | ** | ||||
| Identification of geographies | ** | ||||
| Quarterly loan-to-deposit ratio | ** | ||||
| HMDA written notice to obtain data from CFPB (if HMDA reporter) | ** | ||||
| Consumer loan data | Optional | ||||
| CRA Disclosure Statement (if large Bank, optional if small bank reporting CRA) | ** | ||||
| Other Information | Optional | ||||
| ** Must be available upon request by the customer within 5 calendar days |
