We do not believe that a CRA public notice is required to be posted at your new corporate headquarters, per the discussion below.

The CRA regulations require each institution to post CRA public notices “in the public lobby of its main office and each of its branches.” 12 CFR 228.44. Based on the facts in your question, your corporate headquarters should not be considered to be either a “main office” or “branch,” as those terms are defined for CRA purposes.

For the definition of “main office,” the Interagency CRA Q&As state that “an institution’s main office is the main, home, or principal office as designated in its charter.” Question .43(c)-1. Provided that your corporate headquarters is not listed as your bank’s home or principal office in its charter, (which we are assuming is not the case here), it should not be considered to be your bank’s main office.

For the definition of “branch,” the CRA regulations define the term as “a staffed banking facility approved as a branch.” 12 CFR 228.12(f). Again, since no banking facilities are located in the new headquarters, it should not be considered to be a branch of your bank.