The short answer is two. For those regulated by the Office of the Comptroller of the Currency (OCC), the answer used to be one, but now it is two. As many of you may remember, the OCC “modernized” their CRA regulations in 2020, changing many requirements. Among these were changes to the public notice, which changed from two notices to one notice. Then, in 2021 the OCC rescinded these modernization changes, and reverted back to the pre-2020 regulations. So, once again, there are two versions of the public notice in the OCC’s CRA regulation. The use of two notices was voluntary for OCC regulated institutions from the time that the rescinding of the CRA modernization final rule was effective, but the use of two notices became mandatory on April 1, 2022. Institutions regulated by either the Federal Reserve Board (FRB) or the Federal Deposit Insurance Corporation (FDIC) were not affected by these changes to the OCC’s regulations, as both FRB-regulated and FDIC-regulated banks have used two public notices for years.
At present, the CRA regulations published by the OCC, FRB, and FDIC regulations are similar in their requirements for financial institutions. In Appendix B of their respective regulations are located both a notice for main offices, and a notice for branch offices. The regulations indicate that institutions must display the main office notice in the lobby of its main office and in each of its branches the institution must display the branch office notice. Additionally, for banks that have branches located in more than one state, what the regulations refer to as an “interstate bank,” at least one branch in each state must display the main office notice in the lobby. For example, if a bank is headquartered in Texas, but also has branches in Texas and Oklahoma, then the main office notice would be displayed at the main office in Texas and in one branch in Oklahoma. All other branches in Texas and Oklahoma would need to display the branch office notice.
To help OCC banks with this mandatory compliance item, Compliance Alliance has created templates for both the Main Office notice, as well as the Branch Office notice, which are available for download on our website. We also have CRA public notices for both FRB-regulated (Main Office and Branch Office) and FDIC-regulated banks (Main Office and Branch Office), but as previously stated, the requirements for non-OCC-regulated banks have not changed. Additionally, our CRA toolkit contains dozens of helpful tools such as policies, procedures, checklists, worksheets and training materials. We’re also available on the hotline to answer whatever CRA-related questions you may have.