Topic: Community Reinvestment Act (CRA)
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Has the IDFPR finalized its proposed Illinois Community Reinvestment Act (Illinois CRA) rules?
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No, the IDFPR has not yet finalized its proposed Illinois CRA rules. The IDFPR Division of Banking has indicated that we can expect the rules to be finalized sometime after Labor Day. For resources related to our guidance, please see: IDFPR, Notice of Proposed Rules, Bank Community Reinvestment, 46 Ill. Reg. 19726, 19798 (December 16, 2022)
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Our bank wants to close one hour earlier than we currently close on Fridays. How far in advance do we need to notify our customers of our new hours?
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We are not aware of any Illinois or federal law that requires you to notify customers when altering branch hours. However, we recommend checking your account agreements to ensure they do not include relevant notification requirements. We also recommend posting advance notice of the changed hours in the lobby of any affected branch and on…
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For the Illinois Community Reinvestment Act (Illinois CRA) notice: (1) Can we use a title when listing the name of the “official at bank,” such as “CRA officer,” (2) what title should we use for the “responsible official” at the Federal Reserve Bank from whom consumers may request certain CRA information, and (3) as an FDIC-regulated Illinois bank, should we also provide information for the FDIC?
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The information in your question pertains to the federal CRA notice and is not currently required for the Illinois CRA notice. You should be posting the version of the Illinois CRA notice required under the statutory text of the Illinois CRA or a version using the alternative language that the IDFPR published in an Illinois…
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I am researching the Illinois Community Reinvestment Act (Illinois CRA)’s requirements, but the law only contains one section on the standards banks will be evaluated under to determine whether they are meeting the financial services needs of local communities. Is there a separate document providing more information on banks’ requirements under the law? Also, do small banks have separate rules with which they need to comply?
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Yes, many of the details of evaluations under the Illinois CRA are left to administrative rulemaking by the Illinois Department of Financial and Professional Regulation (IDFPR). The IDFPR’s forthcoming administrative rules will establish the standards for Illinois CRA evaluations of covered banks to determine whether they are meeting the financial services needs of local communities.…
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What kind of notice are we required to give customers if we alter one of our branch’s hours?
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We are not aware of any Illinois or federal law that requires you to notify customers when altering branch hours. However, we recommend checking your account agreements to ensure they do not include relevant notification requirements. We also recommend posting advance notice of the changed hours in the lobby of any affected branch and on…
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We have an investment division within our bank that owns an insurance company. I am not sure if the investment division is considered separate from the bank. Would the investment division and insurance company be considered “affiliates” of our bank under the IDFPR’s proposed Illinois Community Reinvestment Act (Illinois CRA) rules?
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If the Illinois CRA rules for banks are finalized as proposed, they would apply to your investment division and insurance company as “affiliates” if those entities are under your bank’s control or under common control with your bank. The proposed Illinois CRA rules impose community reinvestment obligations on “banks,” defined as Illinois-chartered banks or savings…
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We have a mortgage company that is a third party-originator and does mortgage document preparation and underwriting for all banks under our holding company. Would the proposed administrative rules for residential mortgage lenders under the Illinois Community Reinvestment Act (Illinois CRA) apply to our mortgage company? Also, would our mortgage company be considered an “affiliate” of our bank since they are under the same holding company?
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The Illinois CRA rules for residential mortgage lenders will apply to your mortgage company if it is licensed under the Illinois Residential Mortgage License Act of 1987 and lent or originated 50 or more residential mortgage loans in the previous calendar year. Additionally, if the Illinois CRA rules for banks are finalized as proposed, your…
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The proposed Illinois Community Reinvestment Act (Illinois CRA) rules rewrite the language that must be included on Illinois CRA signage required to be posted at our main locations and branches. Are we required to use this new language now?
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No, the new language for Illinois CRA signage in the proposed Illinois CRA rules is not currently required, as the proposed rules have not been finalized. Additionally, the IDFPR may rewrite the required language when the agency finalizes the Illinois CRA rules. However, your bank should be posting the current version of the Illinois CRA…
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What disclosures are we required to make available on our bank’s website?
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Below is a non-exhaustive list of the disclosures and notices that you may choose to post or may be required to post on your bank’s website. This list may be incomplete depending on the products and services you offer or advertise on your website, some of which may trigger additional disclosure requirements. Privacy Notices The…
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Can public funds be deposited into a bank that has a less than satisfactory Community Reinvestment Act (CRA) rating? We are aware that the Deposit of State Moneys Act restricts state funds from being deposited into banks with such a rating, but what about local funds (such as funds from counties, municipalities, and fire protection districts)?
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No, public funds cannot be deposited into a bank with a less than satisfactory CRA rating under Illinois law. Effective January 1, 2022, the Public Funds Investment Act prohibits public funds from being deposited in a financial institution with a federal CRA rating that is less than satisfactory. The Act defines “public funds” as “funds…