“I’d like to take a look at your public CRA file.”
You never know who will ask for a copy of your CRA (Community Reinvestment Act) public file. And, by law, depository institutions like yours are required to maintain copies of such records and, upon request, allow customers to inspect the files. If a customer wishes to receive his or her own copy of the institution’s CRA public file, the institution must also oblige with this request.
In short, there are a number of obligations pertaining to the CRA public file.
CRA Public File Documentation
As I’m sure you know, the CRA of 1977 was enacted to ensure that FDIC-insured depository institutions (such as national banks, savings associations, and state-chartered commercial and savings banks) are meeting the credit needs of their communities. As the OCC points out here, this legislation is particularly focused on the needs of “low- and moderate-income neighborhoods and individuals.”
As I’m sure you also know, the OCC routinely prepares written performance evaluations of how well banks are complying with CRA regulations. A bank can receive one of four CRA ratings:
- Needs to Improve
- Substantial Noncompliance
The written evaluation also includes supporting documentation for the bank’s rating, which may include additional commentary, facts, and analysis. As pointed out by the Federal Reserve Bank of Atlanta, once an evaluation has been prepared, the “bank’s entire public CRA file must be available at its main office. If your bank operates in more than one state, it must keep a file at one branch office in each of these states.” Furthermore, the OCC states that the public file must also contain “…all written, public comments received for the current year and for the previous two calendar years…” along with “…any bank responses made to the public comments.”
That’s a lot of documentation to keep organized!
Why a Paper-Only Approach Fails
For the sake of discussion, let’s say that your bank has dozens of branches spread throughout the state of Ohio. You work at the main office in Columbus, which is where your CRA public file is physically located. This morning, a customer walked into your Cincinnati branch and asked for a copy of your CRA policy.
What happens next?
Well, if your CRA public file is only in paper document format, you’ll probably have to go to your records room, find the CRA public file, scan and print copies, and have the documentation couriered over to your Cincinnati branch. Once it arrives in Cincinnati, you’ll also want to follow up and make sure the branch actually provides the customer with the necessary information.
Hopefully everything goes to plan, but there are several variables that could go wrong. What if the courier loses the file? What if the branch officer forgets to follow up?
Electronic CRA Management
A more scalable approach involves the use of an electronic CRA file archive. Our AccuDoc system makes it easy to manage and organize all of your CRA documentation. In fact, your bank can build a module in AccuDoc specifically for CRA public files and related compliance information.
When a branch needs to pull your CRA public file, anyone at your bank who has access can log in to AccuDoc, find the latest version, and print the files. No more lost documents or courier expenses. Everything is accessible on your bank’s servers, thanks to AccuDoc.
Better yet, AccuDoc is completely modular, which means you can use it to organize other important documentation. Banks routinely use AccuDoc to manage a variety of files, such as: loan policies, trust policies, compliance policies, exams, investments, qualified services, and much more.
Streamline the Management of CRA Documentation
If you’re tired of worrying about potential compliance issues with your CRA documentation, it’s time you talked to the team at AccuSystems. Our integrated software solutions can help you reduce risk, improve accessibility, and ensure compliance.
Chat now with one of our former bankers.