Is it acceptale to use a modified version of the HMDA LAR (i.e. contains all information except customer names and was not submitted to the FFIEC) as the HMDA disclosure in the public file? I am auditing a bank that due to the number of branches, images the public file on their network file, and due to the bulk of the disclosure from the FFIEC, they went with a modified "in house" version.

We put a modified LAR on in our Public File until our actual disclosure is issued. You just want to make sure there isn't any identifying info in the LAR you put out.

Public Disclosure of Modified Loan Application Register: A finanical institution shall make its loan application register available to the public after removing the following information: (1) the application or loan number; (2) the date the application was received; and (3) the date action was taken. This is done to protect a consumer's privacy.

See 12 CFR 203.5(c) of the Regulation and the associated Staff Commentary

The term "disclosure" statement has a different meaning than the HMDA LAR in the Regulation. Every reporting lender has a disclosure statement that is released by the Fed when the A&D data is published annually in September. The bank is required to make its disclosure statement available in its public file as well as a modified HMDA LAR. So when you mention "disclosure" are you referring to disclosure statement responsibility or are you talking about the requirement to maintain a modified HMDA LAR (which is another requirement of the regulation)?

Can you tell me if the CRA Public File should be updated on a quarterly basis with the modified HMDA LAR or would the year end HMDA LAR suffice?

The HMDA LAR is required to be updated within 30 days of the end of each Quarter. It is not a requirement of CRA to maintain the HMDA LAR in your public file. CRA requires you to maintain the HMDA Disclosure statement in your public file. It is the HMDA regulation that requires you to post your HMDA LAR on a regular basis.

Not necessarily post the LAR but it must be available to the public upon request for 3 years. Some choose to put the modified LAR in their public file for convenience.

Riz- by "post" I meant that you are supposed to maintain your LAR on a regular basis, not make it available to the public. I wasn't referring to the modified LAR.

Sorry, Len! I misunderstood.

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There is a CRA requirement for quarterly updates, as to meeting the community credit needs, if a bank has a low CRA rating.

I haven't been involved with a bank in this position, but I would suppose that with a Needs to Improve, posting a modified LAR might be a part of this update.