Nothing is too small for HMDA so I would like to get this correct.

We submitted our 2010 data on time actually a few days prior to the March 1st deadline. Then, on May 13, 2011 we discovered a minor error and then did a complete resubmission.

In September 2011, when we received notice that the 2010 aggregate data was available we downloaded our bank's disclsoures and placed them in our CRA Public File, etc. (we are FDIC-supervised and a small bank $200MM). The date on the disclsoures states: Report Date 06/03/2011, therefore I assumed our correction from 5-13-2011 was included with that report.

Today, (10/12/2011)I received a new set of HMDA disclsoures from the Fed and the Report Date indicates 10/07/2011. Which set of disclosures do you believe I should include in the CRA Public File- the set dated 6-3-2011 or the set dated 10-7-2011?

Thanks in advance for any responses.

You should place the 10/7/11 disclosures in your public file as those are your accurate disclosures. It looks like they just got to your resubmission and subsequently updated their files.

Keep in mind the Fed will add/correct resubmission data into their aggregate data for about a year and a half after the original submission deadline. Had you resubmitted today (after the data base is up), the Fed would have sent you an e-mail with new disclosures rather than update the public data base and have them available for download. That is their process; they often e-mail you documents for resubmissions rather than update the database. I am surprised they didn't also include instructions to place those disclosures in your public file, which is what I have seen in the past.

Thanks AJ Compliance. I appreciate the response!

I knew there was written guidance on this and I just ran into it again. If you look at the attached link there is an article on resubmissions that clears this up and agrees with what I already said.

A bit late, but worth adding to this post.

http://www.ffiec.gov/hmda/pdf/10news.pdf