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We opened two loan deposit offices (LPOs) this year. Should we include them in our CRA Public File as “branches opened”? The LPOs have not been authorized as branches. – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

We opened two loan deposit offices (LPOs) this year. Should we include them in our CRA Public File as “branches opened”? The LPOs have not been authorized as branches.

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No, we do not believe that you should include the new LPOs with your list of new branches in your CRA public file. An LPO is not considered a branch under the CRA unless it has been authorized as a branch through the regulatory approval process. In addition, Regulation BB indicates that including information about LPOs is optional, but if a bank chooses to include such information, the appropriate place is on the bank’s list of alternative systems for delivering retail banking services.

For resources related to our guidance, please see:

  • Interagency Q&As Regarding Community Reinvestment Act (July 25, 2016) Definitions, Question #2 (“Question: Are loan production offices (LPO) branches for purposes of the CRA? Answer: LPOs and other offices are not ‘branches’ unless they are authorized as branches of the institution through the regulatory approval process of the institution’s supervisory Agency.”)

  • Regulation BB, 12 CFR 345.43(a) (“A bank shall maintain a public file that includes the following information: . . . (5) A list of services . . . generally offered at the bank's branches and descriptions of material differences in the availability or cost of services at particular branches, if any. At its option, a bank may include information regarding the availability of alternative systems for delivering retail banking services (e.g., RSFs, RSFs not owned or operated by or exclusively for the bank, banking by telephone or computer, loan production offices, and bank-at-work or bank-by-mail programs).”)