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#1502013 - 01/28/11 06:17 PM Public File question
COMPLIcated Offline
Diamond Poster
Joined: Mar 2003
Posts: 1,035
OK
We are a HMDA bank and I thought we had to have a copy of our LAR (the modified one for public) in the file as well as the disclosure statements from the FFIEC website.

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CRA
#1502136 - 01/28/11 07:25 PM Re: Public File question COMPLIcated
Kelsey D Offline
Platinum Poster
Joined: Aug 2006
Posts: 516
Ohio
Just the disclosure statements are required in the public file. There are seperate retention requirements for the LAR.
_________________________
Don't make me say, "I told you so!" Sincerely, your friendly Compliance Officer.

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#1502137 - 01/28/11 07:25 PM Re: Public File question COMPLIcated
pacar Offline
Gold Star
Joined: Jul 2007
Posts: 320
Yes:

Section 345.43(b)(2) of CRA:
2) Banks required to report Home Mortgage Disclosure Act (HMDA) data. A bank required to report home mortgage loan data pursuant part 203 of this title shall include in its public file a copy of the HMDA Disclosure Statement provided by the Federal Financial Institutions Examination Council pertaining to the bank for each of the prior two calendar years. In addition, a bank that elected to have the FDIC consider the mortgage lending of an affiliate for any of these years shall include in its public file the affiliate's HMDA Disclosure Statement for those years. The bank shall place the statement(s) in the public file within three business days after receipt.

And from HMDA (Reg C) section 203.5:

(b) Public disclosure of statement. (1) The Federal Financial Institutions Examination Council (``FFIEC'') will prepare a disclosure statement from the data each financial institution submits.
(2) An institution shall make its disclosure statement (prepared by the FFIEC) available to the public at its home office no later than three business days after receiving it from the FFIEC.
(3) In addition, an institution shall either:
(i) Make its disclosure statement available to the public, within ten business days of receiving it, in at least one branch office in each other metropolitan area where the institution has offices (the disclosure statement need only contain data relating to the metropolitan area where the branch is located); or
(ii) Post the address for sending written requests in the lobby of each branch office in other metropolitan areas where the institution has offices; and mail or deliver a copy of the disclosure statement within fifteen calendar days of receiving a written request (the disclosure statement need only contain data relating to the metropolitan area for which the request is made). Including the address in the general notice required under paragraph (e) of this section satisfies this requirement

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