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.
Yes, the new CRA Regulation is still “on hold” by the courts, but that just means the “old” regulation (Appendix G of your current regulation) is still in force and that requires a CRA Public File to be updated by April 1.
Section 43(e) of Appendix G of your institution’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,
- 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 many census tract changes in the past few years so a refresh of the census tract listing in your public file might be in order.
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 put on your bank’s website (this will be required when the “new” CRA regulation is no longer on “hold”; 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.
And while you’re at it, give your Lobby Notice a once-over to make sure it contains all the correct addresses and information.
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.
TCA – A Better Way!
