As you manage and update your CRA Public File, the CRA states that banks should include:
All written comments received from the public for the current year and each of the prior two calendar years that specifically relate to the bank’s or savings association’s performance in helping to meet community credit needs, and any response to the comments by the bank or savings association, if neither the comments nor the responses contain statements that reflect adversely on the good name or reputation of any persons other than the bank or savings association or publication of which would violate specific provisions of law.
What are some examples of complaints the bank receives that could be included in your CRA Public File?
- Limited or no access to branches in low- to moderate-income (“LMI”) census tracts or in distressed or underserved areas
- Lack of access to credit or the denial of loan applications based on a borrower’s income, specifically for LMI individuals
- Limited availability or no bank products or services to support LMI individuals
- Non-approval of a community grant application or donation request
- Offering of high-cost products the bank directly or its third-party partners – such as payday lending, prepaid cards, small-dollar loans, etc. – that could disproportionately impact LMI individuals
- Criticism or a bank merger or acquisition, especially regarding the restriction of services or closing or a branch in a LMI community
- Complaints received from industry groups such as the National Community Reinvestment Coalition regarding the bank’s CRA efforts or in response to a recent CRA Public Examination report
You should be sure to include the bank’s response to CRA-related complaints as well.
Also, positive comments about the bank’s CRA program, products, services, and community support can and should be included in your CRA Public File when received.