We are a state member bank regulated by the Federal Reserve Board (FRB). Are we required to post the Annual Disclosure Statement Notice in our lobby? Or does that requirement apply only to FDIC and OCC regulated banks?

No, your bank is not required to post an Annual Disclosure Statement Notice. The FRB eliminated the requirement to notify the public about the availability of call reports in 1998, when the reports started being available online. The OCC also eliminated its notice requirement, effective April 1, 2017. Banks regulated by the FDIC, however, still are required to post an Annual Disclosure Statement Notice in their lobbies.

For resources related to our guidance, please see:

  • (Repealed) Regulation H, FRB Disclosure of Financial Information by State Member Banks, 12 CFR 208.17 (“This section requires all state-chartered banks that are members of the Federal Reserve System and all other covered institutions: To make year-end Call Reports . . . available to shareholders, customers, and the general public upon request . . . State member banks and other covered institutions shall use reasonable means at their disposal to advise the public of the availability of information pursuant to this section. . . .”)
  • FRB Final Rule, Regulation H, 63 Fed. Reg. 37630, 37635 (July 13, 1998) (“The Board proposed eliminating existing § 208.17, entitled Disclosure of Financial Information by State member banks, from the proposed Regulation H on the basis that call report information for banks is now available through the internet. . . . [N]ow that many private institutions, as well as many public institutions, such as public libraries, offer access to the internet, where such financial information concerning banks can be obtained, the Board does not believe the burden on banks of providing such information continues to be justified, and therefore, is removing existing § 208.17 from the final rule.”)
  • (Repealed) OCC Notice of Availability, 12 CFR 18.7(b) (“In the lobby of its main office and each branch, each national bank shall prominently display, at all times, a notice that any person may obtain the annual disclosure statement from the bank. The notice shall include the address and telephone number of the person or office to be contacted for a copy. The first copy shall be provided without charge.”)
  • OCC Final Rule, 82 Fed. Reg. 8082, 8097 (effective April 1, 2017) (“The information part 18 requires a national bank to disclose is contained in other publicly available documents, such as the Call Report and the Uniform Bank Performance Report. Part 18 is therefore duplicative and unnecessary. We note that the Federal Reserve Board and the former OTS rescinded similar regulations for state member banks and savings associations, respectively. The OTS repealed 12 CFR 562.3 in December 1995 and the Federal Reserve Board eliminated 12 CFR 208.17 in 1998. We did not receive any specific comments on the removal of part 18 and, therefore, adopt the removal as proposed.”)
  • FDIC Annual Disclosure Statement Notice, 12 CFR 350.7(b) (“In the lobby of its main office and each branch, the bank shall at all times display a notice that the annual disclosure statement may be obtained from the bank. The notice shall include at a minimum an address and telephone number of which requests should be directed. The first copy of the annual disclosure statement shall be provided to a requester free of charge.”)