CRA Deadline Approaching
Just a friendly reminder that your Community Reinvestment Act (CRA) Public File must be updated by April 1, 2020. This includes the public files kept at both the main office and each branch location (if applicable). For a full listing of what you should include in your CRA Public File, please refer to §345.43 (FDIC), §25.43 (OCC), or §228.43 (Federal Reserve).
The following items are often overlooked when updating your CRA Public File:
- Any branches opened or closed in the current year and each of the prior two calendar years (including their street addresses and geographies);
- Current services offered;
- Up-to-date transaction fees; and,
- For small and intermediate-small financial institutions only, an up-to-date loan-to-deposit ratio for each quarter of the prior calendar year.
While we’re on the topic of CRA, you may remember our recent blog about the OCC and FDIC’s proposal to modernize the CRA requirements. The comment period was set to end on March 9, 2020; however, it has been extended until April 8, 2020. We encourage you to review the proposal and submit your feedback as this could greatly affect some financial institutions.
Published
2020/03/05
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Amy Kudlacek
Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!