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For the CRA lobby notice, we have to list our affiliated BHCs. But we have an intermediate and a top holding company. Which should we list on the notice? – IBA Compliance Connection

IBA Compliance Connection

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For the CRA lobby notice, we have to list our affiliated BHCs. But we have an intermediate and a top holding company. Which should we list on the notice?

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The CRA regulations require your Community Reinvestment Act (CRA) notices to include the name of your bank holding company (BHC) if you are “an affiliate of a holding company.” 12 CFR 228.44. “Affiliate” is defined as “any company that controls, is controlled by, or is under common control with” your institution. 12 CFR 228.12. Neither the regulation nor the Interagency CRA Q&As address situations in which an institution has multiple affiliates. That said, if there are multiple companies that control your institution, as defined in the “affiliate” definition, then the best route may be to list all of your institution’s BHCs on the notice.