Large Institutions | Public File Checklist

1. There is no need to review each branch or each complete public file during every examination. In determining the extent to which the institution’s public files will be reviewed, consider the institution’s record of compliance with the public file requirements in previous examinations; its branching structure and changes to it since its last examination; complaints about the institution’s compliance with the public file requirements, and any other relevant information.

2. In any review of the public file undertaken, determine, as needed, whether branches display an accurate public notice in their lobbies and the file(s) in the main office and in each state contains:

a. All written comments from the public relating to the institution’s CRA performance and responses to them for the current and preceding two calendar years (except those that reflect adversely on the good name or reputation of any persons other than the institution);

b. The institution’s most recent CRA performance evaluation;

c. A map of each assessment area showing its boundaries, and on the map or in a separate list, the geographies contained within the assessment area;

d. A list of the institution’s branches, branches opened and closed during the current and each of the prior two calendar years, and their street addresses and geographies;

e. A list of services (loan and deposit products and transaction fees generally offered, and hours of operation at the institution’s branches), including a description of any material differences in the availability or cost of services between these locations;

f. The institution’s CRA disclosure statements for the prior two calendar years;

g. A quarterly report of the institution’s efforts to improve its record if it received a less than satisfactory rating in its most recent CRA performance evaluation;

h. The HMDA Disclosure Statement for the prior two calendar years for the institution and for each non-depository affiliate the institution has elected to include in assessment of its CRA record, if applicable; and

i. If applicable, the number and amount of consumer loans made to the four income categories of borrowers and geographies (low, moderate, middle and upper), and the number and amount located inside and outside of the assessment area(s).

3. In any branch review undertaken, determine whether the branch provides the most recent performance evaluation and a list of services generally available at its branches and a description of any material differences in availability or cost of services at the branch (or a list of services available at the branch).

 

SOURCE:  Large Institution CRA Examination Procedures | OCC, FRB, and FDIC | April 2014