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#1774693 - 01/10/13 03:38 PM Branch Signage in Drive-Through Only Branches
Analauditor Offline
Junior Member
Joined: Aug 2005
Posts: 44
Are we required to post the Equal Housing and Home Mortgage Disclosure Act notices in a drive-through only branch? In reading the regulatory requirements and definition of branch, I don't see an exclusion. How do others handle?

Thank-you for your feedback.

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#1774731 - 01/10/13 04:08 PM Re: Branch Signage in Drive-Through Only Branches Analauditor
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
Do you offer loans or take residential ln apps and have a lobby at this branch?
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Opinions are my own and not of my employer.

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#1774779 - 01/10/13 05:01 PM Re: Branch Signage in Drive-Through Only Branches Analauditor
Analauditor Offline
Junior Member
Joined: Aug 2005
Posts: 44
No. Just a stand-alone deposit-taking facility.

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#1774790 - 01/10/13 05:07 PM Re: Branch Signage in Drive-Through Only Branches Analauditor
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
HMDA:

(e) Notice of availability. A financial institution shall post a general notice about the availability of its HMDA data in the lobby of its home office and of each branch office located in an MSA and Metropolitan Division.

If you have no lobby, I see no requirement to post.

Same with the EHL poster, they don't enter the "area":


§ 338.4 Fair housing poster.

(a) Each bank engaged in extending loans for the purpose of purchasing, constructing, improving, repairing, or maintaining a dwelling or any loan secured by a dwelling shall conspicuously display either the Equal Housing Lender poster set forth in paragraph (b) of this section or the Equal Housing Opportunity poster prescribed by § 110.25(a) of the United States Department of Housing and Urban Development's regulations (24 CFR 110.25(a)), in a central location within the bank where deposits are received or where such loans are made in a manner clearly visible to the general public entering the area, where the poster is displayed.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1774848 - 01/10/13 06:01 PM Re: Branch Signage in Drive-Through Only Branches Analauditor
ahou Offline
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ahou
Joined: Aug 2002
Posts: 3,094
I agree with Randy
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Opinions are my own and not of my employer.

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#1774852 - 01/10/13 06:05 PM Re: Branch Signage in Drive-Through Only Branches ahou
Analauditor Offline
Junior Member
Joined: Aug 2005
Posts: 44
Thank-you both for your valuable feedback.

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