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In December 2001, FFIEC approved interagency examination procedures that help examiners assess financial institutions' compliance with the CRA Sunshine Requirements provisions of the Gramm-Leach-Bliley Act (GLBA). The Federal Reserve System's Regulation G (12 CFR 207)1, which became effective on April 1, 2001, implements the GLBA CRA Sunshine Requirements provisions.
Regulation G generally requires nongovernmental entities or persons and insured depository institutions or affiliates that are parties to certain written agreements made in fulfillment of the Community Reinvestment Act (CRA) to (i) make the agreements available to the public and to the relevant supervisory agency and (ii) file annual reports concerning those agreements with the relevant supervisory agency. In addition to describing factors related to the fulfillment of the CRA, Regulation G also provides criteria for determining when an agreement is a "covered agreement," thus triggering the disclosure and annual reporting requirements of the regulation.
The new examination procedures focus first on whether management is sufficiently familiar with the requirements of Regulation G to enable them to identify covered agreements. In the event that management has determined that the institution is a party to one or more covered agreements, the examination procedures then focus on the institution's practices regarding the disclosure of covered agreements and the filing of annual reports, as required by the regulation. Both of these reviews can be accomplished through a discussion with management or by reviewing the institution's policies and procedures regarding Regulation G.
The Board's March 2001 procedures for filing of documents related to the CRA Sunshine Requirements are available on the Board of Governor's website .
The Consumer Compliance Handbook will soon be available on the Board of Governors' website .
The views expressed in this article are those of the author and are not necessarily those of this Reserve Bank or the Federal Reserve System.