community reinvestment act

OCC Banks: Have You Hung Up Your New CRA Lobby Notice Yet?

If your institution is regulated by the FDIC or FRB, you can stop reading here, unless you want to see what could be coming your way in the near future.

The OCC published a final Community Reinvestment Act rule on June 5, 2020 which marks a departure from the OCC, FDIC and FRB being “in sync” with their regulation and examinations under the CRA. That rule became effective on October 1, 2020, with certain sections having effective mandatory dates of January 1, 2023 (large banks) or January 1, 2024 (other than large banks).

One section which was effective on October 1st (12 CFR §25.30) is the requirement for a revised lobby sign. Gone are the “Main Office” and “Branch” notice distinctions; now there is just one notice which, can be found in Appendix B. Make sure you are going to the correct Appendix B looking for the signage. There are now three Appendix Bs. One is the Appendix B effective October 1, 2020. The other two are contained in Appendix C, which are no longer applicable for signage purposes.

The revised notice is a combination of the old Main Office and Branch notices, with additional information, including the option for a website address to obtain the Bank’s public file and a requirement for email address for the Bank’s CRA contact and the Deputy Comptroller ([email protected]). Be sure to double-check the OCC address for your district, as the Central District address changed.

Now, before you start running out to order your new sign, you do have a little time. OCC Bulletin 2020-99, released on November 9, 2020, includes some key provisions for the revised Regulation and includes an FAQ. While the entire document is a great read, FAQ 26 pertains to the CRA notice.

26. When should banks make the public notice required under 12 CFR 25.30 of the June 2020 rule available to the public?

The June 2020 rule’s public notice requirements have a compliance date of October 1, 2020. Banks may comply with the June 2020 rule notice requirements on that date or, at their option, continue to display the notice required under the 1995 rule until March 1, 2021. All banks must comply with the June 2020 rule notice requirements by March 1, 2021. (“Public notice by banks,” 12 CFR 25.30; “Transition provision,” 12 CFR 25.01(c)(5)).

We have included the notice content below. Items in parenthesis should be customized to the Bank, and bracketed text is only required, if applicable.

More information will be forthcoming as TCA analyzes the new rule. TCA is A Better Way to comply! Contact us at [email protected] or (800) 934-7347 if you need assistance with CRA or any other compliance area.

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Revised CRA Notice from Appendix B

Under the Federal Community Reinvestment Act (CRA), the Comptroller of the Currency (OCC) evaluates our record of helping to meet the credit needs of this community, consistent with safe and sound operations. The OCC also takes this record into account when deciding on certain applications submitted by us.

Your involvement is encouraged.

You are entitled to certain information about our operations and our performance under the CRA, including, for example, information about our branches, such as their location and services provided at them; the public section of our most recent CRA Performance Evaluation, prepared by the OCC; and comments received from the public relating to assessment area needs and opportunities, as well as our responses to those comments. You may review this information today by reviewing the public file which is available at (web address and/or physical address at which the public file can be reviewed and copied).

You may also have access to the following additional information, which we will make available to you after you make a request to us: (1) a map showing the assessment area containing a select branch, which is the area in which the OCC evaluates our CRA performance for that particular community; (2) branch addresses and associated branch facilities and hours in any assessment area; (3) a list of services we provide at those locations; (4) our most recent rating in the assessment area; and (5) copies of all written comments received by us that specifically relate to the needs and opportunities of a given assessment area, and any responses we have made to those comments. If we are operating under an approved strategic plan, you may also have access to a copy of the plan.

At least 30 days before the beginning of each quarter, the OCC publishes a nationwide list of the (entity type) that are scheduled for CRA examination in that quarter. This list is available from the Deputy Comptroller (address). You may send written comments regarding the needs and opportunities of any of the (entity type)’s assessment area(s) to (name, address, and email address of official at bank) and Deputy Comptroller (address and email address). Your comments, together with any response by us, will be considered by the Comptroller in evaluating our CRA performance and may be made public.

You may ask to look at any comments received by the Deputy Comptroller. You may also request from the Deputy Comptroller an announcement of our applications covered by the CRA filed with the Comptroller. [We are an affiliate of (name of holding company), a (entity type) holding company. You may request from the (title of responsible official), Federal Reserve Bank of __________________ (address) an announcement of applications covered by the CRA filed by (entity type) holding companies.]

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