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Can CRA notices direct individuals to contact the CRA Officer without a named contact?

Currently I am the Community Investment Act (CRA) Officer for my bank and my name is listed in the CRA lobby notice. I am retiring soon and no one has been appointed to replace me. The sample CRA notices all show a name and address for a bank contact person, but could the notice just direct individuals to contact the CRA Officer without a named contact?

In my experience, regulators and other interested parties have not taken exception to including the title of a person/area instead of listing a specific name. The key is, of course, to ensure that the communication is delivered to the appropriate person/area for handling.

There is no reference or other written documentation on this issue, as this is merely my interpretation based on experience and the actions of other banking institutions. Section § 12 CFR 345.44 states

“A bank shall provide in the public lobby of its main office and each of its branches the appropriate public notice set forth in Appendix B of this part...

Appendix B then states, in part, “You may send written comments about our performance in helping to meet community credit needs to (name and address of official at bank) and FDIC Regional Director. There was a discussion on the ABA Compliance Network asking bankers which one is used at their bank, with some stating they use the title and others using the name of an individual. Both groups state that they have gone through CRA or general compliance examinations, by FDIC or other agencies, with no issues. I would suggest that you decide what course of action you deem appropriate to take considering your specific scenario and the regulatory requirements. Then contact your examination team and get their view on your recommended action. (May 2017)

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