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Were banks to have updated the public CRA notice posted in branches and elsewhere by October 1, 2020, as required by the new rule, or may it do so over a period of time?

The June 5 edition of the Federal Register contained the Office of the Comptroller of the Currency's final rule related to its revised regulations implementing the Community Reinvestment Act (12 CFR 25). The stated date by which banks must comply is October 1, 2020, other than as specified, although §25.01(c)(5) provides a transition provision stating "the OCC may permit a bank to rely on ... procedures, processes, definitions or other element of:" either the new rule or the previous rule. Was a bank to have updated the public notice posted in branches and elsewhere by Oct. 1, 2020, as required by §25.30 of the new rule, or may it do so over a period of time?

Banks may comply by updating the notice or, at their option may "continue to display the notice required under the 1995 rule until March 1, 2021," according to Question 26 of the Nov. 9 OCC Bulletin 2020-99. Banks must "comply with the June 2020 rule notice requirements by March 1, 2021." (December 2020)

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