CRA Public File & Annual Disclosure Statement Deadlines Approaching

Just a friendly reminder that your Community Reinvestment Act (CRA) Public File must be updated by April 1, 2019.  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 by the financial institution in the current year and each of the prior two calendar years;
• Current services offered by the financial institution;
• Up-to-date transaction fees charged by the financial institution; 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.

Also, if your institution is FDIC-regulated, you must make updates to your annual disclosure statement.  This entails having year-end Call Report information for both 2018 and 2017 available to the public by March 31, 2019.  The annual disclosure statement must be signed by an authorized officer of the institution and include the following disclaimer:

This statement has not been reviewed, or confirmed for accuracy or relevance by the Federal Deposit Insurance Corporation.

On a side note, the FDIC proposed to rescind the annual disclosure statement requirements on October 25, 2018.  There has been no final action taken on this as of today’s date. – See update here.

Learn about the Banker’s Compliance Consulting Team.

Published
2019/03/15
Amy Kudlacek