Q: § __.12(f) – 2: Are loan production offices (LPO) branches for purposes of the CRA?
A: LPOs and other offices are not “branches” unless they are authorized as branches of the institution through the regulatory approval process of the institution’s supervisory Agency.
This Interagency Q&A, and others, was released in July 2016.
The 2016 Q&As consolidates and supersedes all previously published “Interagency Questions and Answers Regarding Community Reinvestment,” and were noted as being effective immediately. They may be found here: http://www.ffiec.gov/cra/qnadoc.htm