Certified Regulatory Compliance Manager (CRCM) Exam | Bank's Response to Community Criticism

Bank's Response to Community Criticism

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Question

A bank received a signed letter criticizing its performance in meeting the credit needs of the community, but not adversely reflecting upon any individual bank employee's reputation. What must the bank do with this letter?

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Explanations

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A. B. C. D.

C

The letter received by the bank is known as a Community Reinvestment Act (CRA) comment letter. The CRA is a federal law that requires banks to help meet the credit needs of the communities they serve, including low- and moderate-income neighborhoods. As part of the CRA, banks are required to maintain a public file that includes any CRA comment letters received.

In this case, since the letter criticizes the bank's performance in meeting the credit needs of the community, the bank must retain it in the CRA public comment file. The purpose of the public comment file is to provide transparency and accountability to the community by allowing them to access and review the bank's performance in meeting their credit needs. The file must be made available for public inspection upon request, in the bank's main office or branch.

Option A, to have it reviewed and discussed by the board of directors, is not necessary in this case as the letter does not reflect adversely on any individual bank employee's reputation.

Option B, to file it with the regional office of the bank's federal regulator, is also not necessary in this case as the letter is a CRA comment letter and must be retained in the CRA public comment file.

Option D, to answer it within 10 business days, is not required by the CRA. However, it may be good practice for the bank to respond to the letter in a timely manner and address any concerns raised by the community.