Interagency CRA Q&As

§__.42(c)(2) CRA Data Collection on Commercial and Consumer Leases

§__.42(c)(2) – 3 Q: Are commercial and consumer leases considered loans for purposes of CRA data collection? A3. Commercial and consumer leases are not considered small business or small farm loans or consumer loans for purposes of the data collection requirements in 12 CFR   .42(a) & (c)(1). However, if an institution wishes to collect and maintain data…

§__.42(d) Availability of Affiliate Lending Data for CRA Evaluation

§__.42(d) – 1 Q: If an institution elects to have an affiliate’s home mortgage lending considered in its CRA evaluation, what data must the institution make available to examiners? A1. If the affiliate is a HMDA reporter, the institution must identify those loans reported by its affiliate under 12 CFR part 1003 (Regulation C, implementing HMDA). At…

§__.43(a)(1) Public Comments Received by the Agencies

§__.43(a)(1) – 1 Q: What happens to comments received by the Agencies? A1. Comments received by an Agency will be on file at the Agency for use by examiners. Those comments are also available to the public unless they are exempt from disclosure under the Freedom of Information Act.   Source: Interagency Questions & Answers Regarding Community Reinvestment…

§__.43(a)(1) Required Institution Response to Received Public Comments

§__.43(a)(1) – 2 Q: Is an institution required to respond to public comments? A2. No. All institutions should review comments and complaints carefully to determine whether any response or other action is warranted. A small institution subject to the small institution performance standards is specifically evaluated on its record of taking action, if warranted, in response to…

§__.43(a)(2) Inclusion of Institution Response to CRA Public Evaluation in Public File

§__.43(a)(2) – 1 Q: May an institution include a response to its CRA performance evaluation in its public file? A1. Yes. However, the format and content of the evaluation, as transmitted by the supervisory Agency, may not be altered or abridged in any manner. In addition, an institution that received a less than satisfactory rating during it…

§__.43(b)(1) Inclusion of Institution Affiliate Lending Data in Public File

§__.43(b)(1) – 1 Q: Must an institution that elects to have affiliate lending considering include data on this lending it its public file? A1. Yes. The lending data to be contained in an institution’s public file covers the lending of the institution’s affiliates, as well as of the institution itself, considered in the assessment of the institution’s…

§__.43(b)(1) Maintenance of CRA Disclosure Statement Electronically for Public File

§__.43(b)(1) – 2 Q: May an institution retain its CRA disclosure statement in electronic format in its public file, rather than printing a hard copy of the CRA disclosure statement for retention in its public file? A2. Yes, if the institution can readily print out its CRA disclosure statement from an electronic medium (e.g., CD, DVD, or…

§__.43(c) Public File Institution Main Office

§__.43(c) – 1 Q: What is an institution’s “main office”? A1. An institution’s main office is the main, home, or principal office as designated in its charter.   Source: Interagency Questions & Answers Regarding Community Reinvestment | July 2016

§__.43(c) Maintenance of Public File Online

§__.43(c) – 2 Q: May an institution maintain a copy of its public file on an intranet or the Internet? A1. Yes, an institution may keep all or part of its public file on an intranet or the Internet, provided that the institution maintains all of the information, either in paper or electronic form, that is required…

§__.44 Placement and Size Requirements for CRA Public Notice

§__.44 – 1 Q: Are there any placement or size requirements for an institution’s public notice? A1. The notice must be placed in the institution’s public lobby, but the size and placement may vary. The notice should be placed in a location and be of a sufficient size that customers can easily see and read it.  …