Thread Options
|
#153517 - 01/26/04 08:06 PM
Re: New HMDA Notice
|
Platinum Poster
Joined: Apr 2003
Posts: 933
New York State
|
OK, I'll bite. I read the article, but don't see what has changed. Can you please elaborate? Thanks
|
Return to Top
|
|
|
|
#153518 - 01/26/04 08:32 PM
Re: New HMDA Notice
|
10K Club
Joined: Aug 2002
Posts: 47,673
Bloomington, IN
|
The new notice has the reference to Ethnicity in it.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.
|
Return to Top
|
|
|
|
#153522 - 01/27/04 03:10 AM
Re: New HMDA Notice
|
10K Club
Joined: Oct 2000
Posts: 27,763
On the Net
|
I answered some emails today on this same topic, citing two BOL threads on posting the new signage. Technically the requirement exists now, to post the new text. Since it isn't truly applicable yet, I'd recommend a slight adjustment to the text that should satisfy both a critical customer as well as a regulator. (Though I don't really believe any regulators would balk at the use of older text yet.) This is simple to produce yourself, although your regulator may have these available. The OSC to Reg. C at (5)(e) says an institution may use any text that meets the requirements of the regulation. Some of the federal financial regulatory agencies and HUD provide HMDA posters that an institution can use to inform the public of the availability of its HMDA data, or the institution may create its own posters. If an institution prints its own, the following language is suggested but is not required: "Home Mortgage Disclosure Act Notice The HMDA data about our residential mortgage lending are available for review. The data show geographic distribution of loans and applications; ethnicity, race, sex, and income of applicants and borrowers; and information about loan approvals and denials. Inquire at this office regarding the locations where HMDA data may be inspected." This was discussed on threads here , and here here. I recommend adding the text to the end as well, "To receive a copy of these data, send a written request to: Your favorite bank's name P.O. Box 1 Anytown US 12345 Attn: Best darn Compliance Officer this side of the river" This is to identify where you may have the records if you do not have a complete report at all locations. Also, you could also adjust this to read, "...and information about loan approvals and denials for the year in which that data was gathered." Adding this will explain to someone who inquires this year and until mid-2005, why you do not have all this data. It was not collected for the year they are reviewing. And you would still conform with the law. There is no size requirement for this disclosure so you can easily print, frame and post this yourself.
_________________________
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
|
Return to Top
|
|
|
|
#153525 - 01/27/04 09:55 PM
Re: New HMDA Notice
|
Power Poster
Joined: Jun 2003
Posts: 7,728
Florida
|
Quote:
has anyone EVER had a request to see their CRA file or HMDA LAR?
I had asked our local competition for the CRA Public Disclosure in the early days, and on more than one occation (after the local branch contacted their head office across country) was told the Public Disclosure was confidential information and they couldn't release it.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.
|
Return to Top
|
|
|
|
#153530 - 01/28/04 03:41 PM
Re: New HMDA Notice
|
Diamond Poster
Joined: Oct 2001
Posts: 1,570
Wisteria Lane..
|
We've had requests for our CRA file. A number of these were from college students using the material to write reports.
_________________________
And where is Superman when I need him?
|
Return to Top
|
|
|
|
#153533 - 02/03/04 03:04 PM
Re: New HMDA Notice
|
Diamond Poster
Joined: Jul 2002
Posts: 1,722
Oklahoma
|
I sent a question to the HMDA help to clarify this for us so we are not caught off guard on what disclosure should be posted (we have a compliance exam coming up!), this was there response. The FFIEC is not printing General Notice Posters for 2004. The suggested language for the 2004 General Notice Poster is available at the following link for your review: http://www.ffiec.gov/hmda/poster.htmWe recommend that you revise the language when the applicable data is available for distribution. (2004 data will be available for distribution mid year 2005). I've gone ahead and provided the language below. The following shows the language found in the link above: HOME MORTGAGE DISCLOSURE ACT NOTICE (for 2004) The HMDA data about our residential mortgage lending are available for review. The data show geographic distribution of loans and applications; race, gender, and income of applicants and borrowers; and information about loan approvals and denials. Inquire at this office regarding the locations where HMDA data may be inspected. HOME MORTGAGE DISCLOSURE ACT NOTICE (for 2005) The HMDA data about our residential mortgage lending are available for review. The data show geographic distribution of loans and applications; ethnicity, race, sex, and income of applicants and borrowers; and information about loan approvals and denials. Inquire at this office regarding the locations where HMDA data may be inspected. **Dont forget: Additional language for institutions making the disclosure statement available on request. An institution that posts a notice informing the public of the address to which a request should be sent could include the following sentence, for example, in its general notice: "To receive a copy of these data send a written request to [address]."
|
Return to Top
|
|
|
|
#153534 - 02/04/04 01:25 PM
Re: New HMDA Notice
|
Platinum Poster
Joined: Apr 2003
Posts: 933
New York State
|
Quote:
I sent a question to the HMDA help to clarify this for us so we are not caught off guard on what disclosure should be posted (we have a compliance exam coming up!), this was there response.
The FFIEC is not printing General Notice Posters for 2004. The suggested language for the 2004 General Notice Poster is available at the following link for your review: http://www.ffiec.gov/hmda/poster.htm We recommend that you revise the language when the applicable data is available for distribution. (2004 data will be available for distribution mid year 2005).
I sent the same question to HMDA Help and was told that I should make the new notice available 01/01/2004.
I'd call it "HMDA HELPLESS".
|
Return to Top
|
|
|
|
#153536 - 02/05/04 08:33 AM
Re: New HMDA Notice
|
Power Poster
Joined: Jun 2001
Posts: 8,272
Where the heart is
|
Logistically, what a nightmare to be changing the HMDA poster two years in row in all of your branches. If you only have a couple of branches, that's one thing. But if you have a bunch, it's like herding cats everytime you need to change a disclosure sign! I think for the "transition" time" (2004 through 3/30/2005), you should be okay regardless if you post the "old" HMDA sign or the new one. Talk about a ticket trap at exam time! Do they think we can simply snap a finger and the new sign will jump into the wall frame? Oh where is Samantha Stevens when you need her?
_________________________
CRCM,CAMS Regulations are a poor substitute for ethics. Just sayin'
|
Return to Top
|
|
|
|
#153538 - 02/05/04 02:38 PM
Re: New HMDA Notice
|
Anonymous
Unregistered
|
We started collecting HMDA data on Jan 1, 2004. If someone does come in and request to see the data do we have to compile what we have accumulated up to that date or do we inform them that all disclosure material will be available in January 2005?
|
Return to Top
|
|
|
|
#153539 - 02/05/04 02:53 PM
Re: New HMDA Notice
|
Diamond Poster
Joined: Jul 2002
Posts: 1,722
Oklahoma
|
Quote:
We started collecting HMDA data on Jan 1, 2004. If someone does come in and request to see the data do we have to compile what we have accumulated up to that date or do we inform them that all disclosure material will be available in January 2005?
No, your HMDA LAR modified reports are an aggregate of information obtained throughout the previous year. You will not have any information to report or make available until 2005.
|
Return to Top
|
|
|
|
#153540 - 02/05/04 04:16 PM
Re: New HMDA Notice
|
10K Club
Joined: Oct 2000
Posts: 27,763
On the Net
|
I can't see changing the sign twice and for that reason recommend the minor text modification as to what is available and when. In my 21 years in the bank I NEVER had a request. The CRA was another matter. One church group asked to see it but had no idea what they were looking at. And once every few years a college student would ask about it for research. Making HMDA data available is an outdated and near manual mode that is rendered useless by the Net. The groups that do want this data go to a consolidated source. And that is fine. If this notice were no longer required and was in fact removed, your customers and staff would see how the paneling faded when the sign was removed. Guess you could hang the presidents picture in its place.
_________________________
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
|
Return to Top
|
|
|
|
|
|