The sample poster language in the HMDA commentary has changed to include the availability of ethnicity information. I'm curious as to when other banks will be revising their lobby signage? Will you do it in early 2005 when the ethnicity data is actually available to the public?

The signs are available from vendors now. We have ordered them and will be in place at the end of 2003.

That's a good question. I think I'd rather deal with the remote possibility that someone will ask for data and then be upset that it doesn't include ethnicity information, than try to explain to an examiner that I chose not to use the new language because I did not actually have ethnicity data available for review.

The notice under 5(e) is suggested text, not required. You could easily add something to the effect of "Information obtained in one year will be available the following year."

This would both meet regulatory expectations and inform a consumer/group that this year's data is available next year. So if there is new data in 2004, it is available in 2005+. Also, by not using 2003, etc. maintenance is low and you don't have to mark next years calendar to update the sign.

We ordered our signs already and will put them up in 2004, easier then making sure we don't forget in 2005...

forgot to login.. HI Andy... enjoyed meeting you in Norman.

Can anyone share their vendor's name? Please.

I ordered ours from Bankers Systems...

I would just get the new notices. How many people actually ask for it and of those, how many will question the missing ethnicity info?

Do we have to have a lobby notice if our bank is NOT subject to HmDA?

No. If you do not meet the HMDA thresholds then you are not subject to Reg. C.

Does the HMDA notice have to placed in "every" branch office or only certain offices?

Post a general notice about the availability of your HMDA data in the lobby of your home office and in each branch office located in an MSA and Metropolitan Division.

Am I reading this correctly that a notice posted in our branches such as "inquire at this office about how to obtain a copy of this data" would satisfy 203.5(e). But it would have to be more specific, i.e., disclose a specific address, to comply with 203.5(b)(3)(ii)?

Why not just put on your poster the wording like: The Home Mortgage Disclosure Statement is available for inspection at the location listed below. To obtain a copy please send a written request to: And then list trhe name, dept. and tel no. The HMDA reg. gave us this option several years ago and the examiners have said this is o.k. This keeps us from having to revise our posters all the time.

Thanks for confirming my thoughts as well.