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Obtaining the bank's CRA
(AKA "Getting Even")
Turn the tables on your bank. Similar to how a bank can pull a report that has information about your past, you can easily pull a report that has information about your bank's past. Each branch of each bank is required to provide to you information about how well that branch meets the credit needs of your community. This requirement is part of the federal Community Reinvestment Act. (Note - credit unions are execpt from CRA requirements.)

We are helping to coordinate a CRA hit squad which focuses on one bank at a time in hopes of convincing the banks to reconsider their policies regarding ChexSystems. We've started the CRA Hit Squad Message Board to help coordinate which banks to hit and when, and know which branch locations have already been hit. The message board allows anonymous posts, so everyone should feel comfortable participating.

Here are step-by-step instructions on what to do:
1.) Plan an opportune time. If the bank is really busy, they will notice the interruption even more. 4:30 pm on a Friday always seems to be a good time.
2.) Bring a microcassette tape recorder with you. Should the bank be less than willing to cooperate. a recorder will help convince them that you are familiar with the regulations and that your taped conversation would be used should you need to report them to the regulatory authorities.
3.) Print out some supporting documents which you may need to help your bank remember what they are required to do. Print out the Federal Reserve's CRA web page (specifically, page five) which states clearly what your bank must provide. Also, consider printing out our CRA Hit Squad explanation page which you can present to the banker after you are done to help inform them that their ChexSystems policy needs to be reconsidered.
4.) When you visit the bank, go to the information desk or, preferably, walk up to any teller and ask to see the bank's CRA (Community Reinvestment Act) Files. The bank is required to have this available for you to inspect at no charge, any time the bank is open. They generally will already have a folder ready and waiting.

This document should be updated each year so if the copy you are shown is an evaluation dated more than 12 months ago, you will want to ask them for the most recent copy. (They probably will need to contact their CRA coordinator to get an updated copy delivered to them.)

5.) This folder probably will not have any location- specific information. That information is normally just kept by the CRA coordinator at the bank's headquarters. This location-specific information will include:
- a map of the bank's assessment area showing its
  boundaries and identifying the various geographic
  areas within it.
- all written comments from the public
  (and the bank's response to each) about how the
  bank is helping meet community credit needs.

What you want to do is to ask for "the information in the public file relating to that branch's assessment area". To meet that request, generally, the branch manager ends up contacting the CRA coordinator at the bank's headquarters, who then needs to make copies of a bunch of documents and courier them to the bank branch where your request was made. They have five [business] days to make these documents available to you for you to inspect. The bank cannot refuse to do this for you without breaking federal CRA law.

(Your banker may not know what you are asking for, as they don't receive this type of request all that often. But be persistent, as federal law mandates that these files be made available to you. If the bank says you need to visit a different branch, show them page 5 of the CRA document you printed out. It is up to them to get the documents sent to your branch location. If the bank says there is a charge, let them know that you can only be charged if you are asking for a copy to take home. If you are going to simply inspect their copy on-premises at the bank, they cannot charge you a dime. Here are some other documents that you might want to direct them to: A Banker's Quick Reference Guide to CRA and A Guide to Small Bank Public Performance Evaluations Under the CRA, both of which are made available by the Dallas branch of the Federal Reserve.)

6.) Go back to the CRA Hit Squad Message Board and post which branch location you visited. The efforts of the CRA Hit Squad will be more effective when many different branch locations of the same bank are visited within a short time. The impact is minimal when a single location is hit twice as the file obtained during the first request can be used to satisfy subsequent requests. So please make sure to provide the follow-through posting.
7.) Write a letter to your bank and ask that the letter be included in the bank's CRA public file. The topic of your letter might be something along the lines of how you believe the bank is not serving the credit needs of the community because of their ChexSystems policy.

Since the banks won't listen to us normally, we use this wonderful tool known as the CRA files to help get our message across. When we communicate and coordinate, we will make a difference.

On a related not, see the Hunt For Wells Fargo Bank's 'Do No Call' Policy which documents a similar effort.



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