IBA Compliance Connection

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The FDIC’s lobby notice under the federal Community Reinvestment Act (CRA) states in part, “You may request from the (title of responsible official), Federal Reserve Bank of _______ (address) an announcement of applications covered by the CRA filed by bank holding companies.” What is the title of the responsible official from the Federal Reserve Bank of Chicago referred to here?

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For an FDIC-regulated Illinois bank, the responsible official’s title is “Officer in Charge of Supervision.”

The federal banking agencies have released Interagency Guidance regarding the CRA public lobby notice. The Interagency Guidance directs FDIC-supervised institutions to list the “Officer in Charge of Supervision” as the responsible official for Federal Reserve Banks. We have reached out to the Federal Reserve Bank of Chicago in the past, and at that time they confirmed that this title should be used in the CRA notice. In addition, they confirmed that the address for the Federal Reserve Bank of Chicago is 230 South LaSalle Street, Chicago, Illinois, 60604.

For resources related to our guidance, please see:

  • 12 CFR Appendix B to Part 345(a), CRA Notice (“You may request from the (title of responsible official), Federal Reserve Bank of _______(address) an announcement of applications covered by the CRA filed by bank holding companies.”)
  • Interagency Questions and Answers Regarding Community Reinvestment, 81 Fed. Reg. 48505, 48556 (July 7, 2016) (“OCC-, FDIC-, and Board-supervised institutions: ‘Officer in Charge of Supervision’ is the title of the responsible official at the appropriate Federal Reserve Bank.”)