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#153541 - 02/05/04 04:42 PM Re: New HMDA Notice
MackenzieS Offline
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MackenzieS
Joined: Jul 2002
Posts: 1,722
Oklahoma
If it were not for an upcoming compliance exam I would not change ours at all (until 2005). Thankfully we only have three branches so this is not much of an inconvenience to remove and replace the posters.

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Lending Compliance
#153542 - 02/05/04 04:43 PM Re: New HMDA Notice
Anonymous
Unregistered

So has anyone heard how the OCC views this change? We don't want to be blindsided by the examiners either. Since we can write our own, why wouldn't the old ones satisfy teh requirement until next year?

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#153543 - 02/05/04 06:16 PM Re: New HMDA Notice
Andy_Z Offline
10K Club
Andy_Z
Joined: Oct 2000
Posts: 27,754
On the Net
Personally, I can't see a good examiner getting upset at either. But technically the new notice, premature as it is, is the required notice. You don't have to be exactly as the sample, however. Hence you can tweak it.

If I was going to post the old or the new, you can't be faulted for using the new even if it is incorrect. You could get into an argument over using the old, however. I know it doesn't make sense. Its just the reg.
_________________________
AndyZ CRCM
My opinions are not necessarily my employers.
R+R-R=R+R
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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