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#2131449 - 05/23/17 01:24 PM HMDA Notice
peony Offline
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peony
Joined: Mar 2013
Posts: 250
Are you going to update your HMDA notice? It states that it is suggested but not required. Not sure if it is something that we should do even though it's not required.

Thanks.

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#2131502 - 05/23/17 03:59 PM Re: HMDA Notice peony
Reg Warrior Offline
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We will be updating our notice using the "suggested" text.

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#2132996 - 06/02/17 09:18 PM Re: HMDA Notice peony
cle Offline
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Posts: 161
When do you plan on posting the new notice?

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#2132998 - 06/02/17 09:46 PM Re: HMDA Notice peony
Reg Warrior Offline
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We have the new notice scheduled to printed in January and to be in all locations by the end of February.

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#2133004 - 06/02/17 11:39 PM Re: HMDA Notice peony
Darth HMDA, CRCM, CAMS Offline
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ours will be printed end of the year and put up Jan or Feb
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#2140620 - 08/03/17 02:59 PM Re: HMDA Notice peony
spidergirl Offline
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Posts: 20
Question with the new HMDA Rules coming in January of 2018, one of the requirements is for a new lobby poster to be displayed in each lobby and branch. In addition to the new poster, you must provide a written notice to the public upon request. Does anyone believe that this requires a “take-on” kind of notice that the customer take as needed, as WKFS is saying? I have never seen this before and we have always just had the poster and the notice on our website.

Thank you in advance for your thoughts.

http://www.wolterskluwerfs.com/regulatory-analytics/hmda-poster.aspx

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#2140721 - 08/03/17 08:53 PM Re: HMDA Notice peony
David Dickinson Offline
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David Dickinson
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Central City, NE
§1003.5(e) states:

Posted notice of availability of data.
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 physically located in each MSA and each MD. This notice must clearly convey that the institution's HMDA data is available on the Bureau's Web site at www.consumerfinance.gov/hmda.


Can you tell me where the regulation requires a "take-one" notice? I read the WK notice, but don't agree.
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#2140766 - 08/04/17 12:51 PM Re: HMDA Notice David Dickinson
spidergirl Offline
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That is exactly what I'm trying to find out and I don't agree either. I have never seen a "take-one" requirement. Not sure where they got that from, just wanted to make sure I wasn't missing anything.

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#2141154 - 08/08/17 02:14 AM Re: HMDA Notice peony
RVFlyboy Offline
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Opportunity for WK to sell pad refills. Definitely not required.
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#2141165 - 08/08/17 12:22 PM Re: HMDA Notice peony
Monster Offline
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Beech is so right - I feel like they were once a trusted company but now they're leaning towards profit more than expectations.

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#2144148 - 08/29/17 09:14 PM Re: HMDA Notice peony
bOaty Offline
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Chillin an grillin
On page 90 of the SEG Section 6.3.2 Modified LAR

"Beginning in 2018, upon request from a member of the public, a Financial Institution must provide a written notice regarding the availability of its modified LAR........................."

It goes on to say that we may use the sample notice language and then states that the notice must be made available in paper or electronic form. Comment 5(c)-1.

So does this not seem like we should be handing them a notice either on paper or electronically?
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#2144237 - 08/30/17 03:39 PM Re: HMDA Notice peony
RVFlyboy Offline
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I stand corrected - we are required to provide them a written notice if they ask for the HMDA LAR. See this thread: https://www.bankersonline.com/forum/ubbt...res#Post2144086
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#2144513 - 08/31/17 04:40 PM Re: HMDA Notice peony
David Dickinson Offline
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I wasn't aware of this either. There's a more detailed discussion going on in the link BeechFlyboy provided.
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#2144592 - 08/31/17 08:40 PM Re: HMDA Notice peony
John Burnett Offline
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1003.5(b)(2) and 1003.5(c)(1), taken with 1003.5(d).
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#2151218 - 10/26/17 01:24 PM Re: HMDA Notice John Burnett
Summer101 Offline
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Posts: 644
Just to clarify, we do need to remove our old HMDA lobby notice and replace it with the revised notice that includes the CFPB's website as of 1/1/18, correct?

I ask because technically the modified LAR for 2017 and earlier would be obtained from the bank rather than the CFPB's website so the revised notice seems to be somewhat misleading.

Thanks!!

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#2151237 - 10/26/17 02:30 PM Re: HMDA Notice peony
Bville Offline
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Bville
Joined: May 2001
Posts: 1,282
Out West
There is HMDA stuff about my bank on the CFPB website going back for years so I was hoping we could post the new notice and keep the new notice handy starting on 01/01/18 and not bother with providing the modified LAR at the bank.

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#2151241 - 10/26/17 02:43 PM Re: HMDA Notice peony
burke116 Offline
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We are posting only the new notice starting 1/1/2018.

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#2151246 - 10/26/17 02:52 PM Re: HMDA Notice burke116
NSF, CRCM Offline
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Originally Posted By burke116
We are posting only the new notice starting 1/1/2018.


We are doing the same. The way I see it is as of 1/1/2018, the old notice language is gone from the regulation, so any requirement to keep it up is gone as well.
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#2152447 - 11/06/17 10:23 PM Re: HMDA Notice peony
ComplianceRegs Offline
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So informal poll. Are most just posting the current notice and not concerning themselves with how they get data for years prior to 2017? Was thinking about adding a blurb in the updated notice to say "data for years prior to 2017 are available by inquiring at this office" or something similar to that. What are you guys doing to address the gap? Or is everyone taking the stance NSF outlined that this is no longer in the reg so it is no longer a concern?
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#2152449 - 11/06/17 10:25 PM Re: HMDA Notice peony
Sunshine Lady Offline
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We are just posting the notice that refers them to the CFPB.
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#2156309 - 12/06/17 08:16 PM Re: HMDA Notice peony
Aruba123 Offline
Member
Joined: Jan 2012
Posts: 69
New York
I am reading here that we are required to provide the HMDA notice to the requester "in hand". Isn't this required if they ask for the modified LAR? Am I reading the Small Entity Guide wrong?

6.3.2 Modified LAR
Effective January 1, 2018, the HMDA Rule changes a Financial Institution’s obligations with respect to disclosing its modified LAR. The new requirements apply to data collected in 2017 and later years.
Beginning in 2018, upon request from a member of the public, a Financial Institution must provide a written notice regarding the availability of its modified LAR.

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#2156373 - 12/07/17 08:10 AM Re: HMDA Notice peony
Kathleen O. Blanchard Offline

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Just having a poster is not enough. The disclosure notice must be given to anyone requesting the 2017 or forward LAR or disclosure statement. They must walk away with something in their hand.
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#2156374 - 12/07/17 08:13 AM Re: HMDA Notice peony
Kathleen O. Blanchard Offline

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Years prior to 2017 are covered by the current (pre2018) rules and will continue to be until they "age off" of needing to be made available. They are not going to be electronically available at the CFPB website. The poster language is not mandatory and you can either insert language about pre-2017 years or have two posters that clearly say what years are covered for what method.

The longest time for the "old way" is 3 years for the LAR and 5 for the disclosure statement for the 2016 data.
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#2156393 - 12/07/17 01:55 PM Re: HMDA Notice peony
Aruba123 Offline
Member
Joined: Jan 2012
Posts: 69
New York
Thank you Kathleen!

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#2156472 - 12/07/17 05:59 PM Re: HMDA Notice Kathleen O. Blanchard
David Dickinson Offline
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David Dickinson
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Central City, NE
Quote:
Just having a poster is not enough. The disclosure notice must be given to anyone requesting the 2017 or forward LAR or disclosure statement. They must walk away with something in their hand.

You can also email them the notice.
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