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#174265 - 03/29/04 03:49 PM HMDA Signage
Bear Collector, CRCM Offline
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Bear Collector, CRCM
Joined: Nov 2000
Posts: 1,830
District of Columbia
Does the HMDA lobby signage need to be changed to add the term "ethnicity"?
For example -
"The data show geographic distribution of loans and applications; [ethnicity] race, gender, and income of applicants and borrowers; and information about loan approvals and denials."
If the signage must be changed, by what date? I heard that it had to be changed by March 2005, but I am not too sure about my source of information.
Being kind is more important than being important.

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Lending Compliance
#174266 - 03/29/04 03:56 PM Re: HMDA Signage
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
Technically the sign should have been up by 1/1/04, but there has been discussion in other threads that people have spoken with their regulators and were told the 3/05 date and others the 1/1/04 date.

I would advise talking with your examiners. FWIW we had the new sign in place on 1/2/04.
The opinions expressed are mine and they are not to be taken as legal advice.

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#174267 - 03/29/04 03:58 PM Re: HMDA Signage
Beagles22 Offline
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Joined: Jan 2004
Posts: 3,626
State of confusion
Yes, the new signs I believe have to be up now, and they did add the word ethnicity right after the word applications. I thought they needed to be up by April 1 but that could be wrong too! I know we ordered our new ones in February as we have an audit coming up!!!
Going to church doesn't make you a christian any more that standing in your garage makes you a car.

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#174268 - 03/29/04 04:20 PM Re: HMDA Signage
Andy_Z Offline
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Joined: Oct 2000
Posts: 27,754
On the Net
The technical answer is the new notice should be up. The "useful" answer is that it doesn't apply yet.

My recommendation in this thread is to slightly amend the text so that you a) conform to the regulatory requirement, b) inform the reader that all data may not yet be available and c) don't have to worry about changing it multiple times, or for that matter worry about changing it again at all.
My opinions are not necessarily my employers.
Rules and Regs minus Relationships equals Resentment and Rebellion. John Maxwell

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