Practus Pointer: OCC Banks Have Until April 1 to Revise CRA Public Notice & File

MAR 23, 2022 | PRACTUS LLP

Practus Pointer: OCC Banks Have Until April 1 to Revise CRA Public Notice & File

Authored by Andrea J. Shaw

They say if you wait long enough, everything comes back again.  This is why my closet is overflowing with things like my favorite navy blue, pink and white argyle sweater from the last time argyle was “in”.  With the OCC and its Community Reinvestment Act (“CRA”) public notice and public file requirements, banks didn’t have to wait all that long for what’s old to be new again!

In June 2020, the OCC issued a final rule (2020 Rule) amending its Community Reinvestment Act regulation. Among other things, it modified the public notice that banks must display in both the main and branch offices as well as the contents of the public file that banks must make available upon request. These changes were required to be made by October 1, 2020. (See OCC Bulletin 2020-99 Questions 25 and 26)  In December 2021, the OCC issued a new final rule (2021 Rule) rescinding the 2020 Rule, yet again amending the public notice and public file requirements.  These changes must be implemented by April 1, 2022 and revert the requirements BACK to what they were prior to the 2020 final rule. 

This means banks that dutifully modified their CRA public notice and file to comply with the 2020 revisions (which required less information), must yet again update the public notice and file by April 1, 2022 to revert to the pre-2020 requirements. The OCC clarified this position in Bulletin 2022-4 (See Question #25). 

Great news, argyle sweater, it’s still chilly in Maine, and you’re back in for 2022!

The Authors
Andrea J. Shaw
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Practus, LLP provides this information as a service to clients and others for educational purposes only. It should not be construed or relied on as legal advice or to create an attorney-client relationship. Readers should not act upon this information without seeking advice from professional advisers.

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