Topic: Community Reinvestment Act (CRA)
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We make multi-family mortgage loans within our assessment area from NSP funds. Can we report these loans as community development loans? We qualify as a large bank for CRA purposes.
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We believe you may report your multi-family mortgage loans originated through HUD’s Neighborhood Stabilization Program (NSP) as “community development loans” for purposes of the Community Reinvestment Act (CRA) if the loans meet certain requirements in the CRA rules. Since your financial institution is a large financial institution, this will impact your CRA lending analysis under…
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After receiving a letter from the FDIC closing a written consumer complaint about our institution, are we required to keep it in a public consumer complaint file?
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We are not aware of any requirements to maintain a public file of consumer complaints, except other than Consumer Reinvestment Act-related complaints. The Community Reinvestment Act (CRA) requires institutions to place in a public file any complaint that might “specifically relate to the bank’s performance in helping to meet community credit needs” 12 CFR 345.43(a)(1).…
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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…
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Are there any regulations/approvals or time frames we would need to be concerned with if we reduce our current drive up hours? Lobby hours would remain unchanged.
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We are not aware of any laws that address a reduction in hours for a drive-up facility, and we can only make suggestions as to reputation risk and CRA risks. The Illinois Promissory Note and Bank Holiday Act imposes duties when a bank plans to close a branch on a particular day each week, but…
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We are looking at changing our hours of operation at several of our locations. Are there any notification requirements in Illinois that are required prior to this change?
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We are not aware of any laws that address a reduction in branch hours, and we can only make suggestions as to reputation risk and CRA risks. The Illinois Promissory Note and Bank Holiday Act imposes duties when a bank plans to close a branch on a particular day each week, but it is silent…
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We would like to participate in the Assets for Independence Program. How should we set up these accounts?
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It appears that the Illinois Assets for Independence Program is currently on hold. Several weeks ago, we contacted the Department of Human Services, which administers the program, we were told that Illinois cannot afford the program right now, particularly because it requires the state to match any federal funds provided on a three-to-one basis. The…