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Compliance question of the month: When do changes to CRA’s public file requirements go into effect?

March 15, 2024
Reading Time: 1 min read

I am confused about when the “public file” provisions of revised Regulation BB (Community Reinvestment Act rule’s: §228.43, Federal Reserve, §25.43, OCC, §345.43, FDIC) go into effect.

Q Can you please clarify?

A The provisions of revised Regulation BB that require banks to make available their “public file” (their most recent CRA performance evaluation, written comments from the public about how the bank is meeting its community credit needs, the bank’s assessment area, etc.) are scheduled to go into effect on April 1, 2024.

However, ABA and other trades have challenged the final rule in court and have requested a preliminary injunction – an order that will pause the rule’s effective dates while the case is pending. Though the mandatory effective date for the public file provisions could be delayed, it is not possible to predict when the judge will decide whether to grant the injunction, so banks should prepare to meet the April 1, 2024 deadline.

For more information, contact ABA’s Rhonda Castaneda.
Please note that this section is not a substitute for professional legal advice.

Tags: Compliance
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