No more last-minute updates to your CRA “Public” File…now the file will actually be PUBLIC!
In October 2023, the Federal banking agencies adopted significant revisions to the Community Reinvestment Act. The majority of these revisions are applicable January 1, 2026, and January 1, 2027. However, the following provisions, which are similar to the current CRA regulations, are effective April 1, 2024: facility-based assessment area delineations, effect of CRA on applications, public file availability and location, bank public notice, and CRA examination schedule public notice provisions, as well as the new public engagement provision.
While certain provisions were not substantively changed, one change has immediate and significant impact:
Availability and Location of the CRA Public File
Historically, CRA public files may have collected dust on the shelf in between audits and exams, but now for banks that maintain a website, all information required for the CRA public file must be maintained on the bank’s website. That means items such as loan-to-deposit ratios and other public file content requirements will necessitate more frequent updates, as anyone, including auditors and examiners, may peek into the bank’s public file at any point during the year.
Click here to read the Final Rule.
Email info@sentryadvisory.com with any questions – we hope to hear from you!
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