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#2144086 - 08/29/17 06:47 PM Take One HMDA Disclosures
bOaty Offline
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Can everyone please weigh in on how your handling the disclosure notice that must be handed to the people who ask about getting a copy of the HMDA data?


I can't imagine having a stack of notices ready to be given out should someone happen to ask. Then again, I can't imagine that anyone will know what to do should someone ask for it.

Looking for options and ideas.
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#2144122 - 08/29/17 08:27 PM Re: Take One HMDA Disclosures bOaty
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I'm pretty sure a "Take One" notice is not required...there was a thread on this not too long ago.

https://www.bankersonline.com/forum/ubbthreads.php/topics/2131449/hmda-notice#Post2131449
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#2144139 - 08/29/17 09:03 PM Re: Take One HMDA Disclosures bOaty
waldensouth Offline
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FINALLY ABOVE the gnat line
The Notice should replace your HMDA lobby signage.
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#2144150 - 08/29/17 09:17 PM Re: Take One HMDA Disclosures bOaty
bOaty Offline
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But is says on page 91 of the SEG, in the second paragraph that if someone requests your modified LAR you must give them, in either paper or electronic form, a copy of the notice. It can be the same verbiage as the sample language on the posted but it does clearly state it must be made available in paper or electronic form. I do not think that pointing at the lobby sign fulfills this requirement.

What are we all missing here?
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#2144152 - 08/29/17 09:18 PM Re: Take One HMDA Disclosures bOaty
bOaty Offline
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Or what am I missing?

Either way. smile
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#2144157 - 08/29/17 09:25 PM Re: Take One HMDA Disclosures bOaty
David Dickinson Offline
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says on page 91 of the SEG
Can you give a link? I don't know what a SEG is. I'm not familiar with this "requirement".
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#2144158 - 08/29/17 09:29 PM Re: Take One HMDA Disclosures bOaty
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#2144173 - 08/29/17 10:04 PM Re: Take One HMDA Disclosures bOaty
waldensouth Offline
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I wonder if just posting it on your bank's website would be sufficient. It would be an electronic notice.
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#2144177 - 08/29/17 10:32 PM Re: Take One HMDA Disclosures bOaty
bOaty Offline
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I'm not sure. I suppose if the request was made electronically you could email them an electronic copy or a link to the website. But in person I'm not sure if this would fly. They don't give any other details.

Of course we'll spend all of this time trying to figure out what to do for this requirement and no one will ever ask anyway. crazy
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#2144178 - 08/29/17 10:52 PM Re: Take One HMDA Disclosures bOaty
Kathleen O. Blanchard Offline

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You must have your poster, but if someone comes in with a request, you also must give them a written notice so that they leave with something that has instructions on it.

From the discussion in the final rule published in 2015:

Two industry commenters suggested that, because disclosure statements are available on the FFIEC Web site, requiring financial institutions to provide members of the public seeking HMDA data with the notice under proposed § 1003.5(b)(2) was unnecessary and duplicative. One of these commenters suggested that, as an alternative to the notice required under proposed § 1003.5(b)(2), the Bureau should revise the posted lobby notice required pursuant to § 1003.5(e) to include text referring members of the public to the FFIEC Web site to obtain the institution's HMDA data. Although the final rule relieves financial institutions of the obligation to provide the disclosure statement directly to the public, the Bureau has determined that provision of the notice required under § 1003.5(b)(2) to a member of the public seeking a financial institution's disclosure statement is necessary to ensure that she is clearly informed of where to obtain it. Currently, a member of the public seeking a disclosure statement from a financial institution would leave the institution with the data in hand. As amended, § 1003.5(b)(2) requires that the individual take an additional step to obtain the data—visit the Bureau's Web site—but provides that she leaves the institution with the specific information needed to do so.
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#2144179 - 08/29/17 11:22 PM Re: Take One HMDA Disclosures bOaty
bOaty Offline
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Thanks, Kathleen.

So back to the original post. I'm looking to see what others are planning on doing to meet this requirement.

Discuss.

Thanks!!
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#2144180 - 08/29/17 11:39 PM Re: Take One HMDA Disclosures bOaty
Darth HMDA, CRCM, CAMS Offline
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I wish we could say "Please google CFPB & HMDA" hahaha smile
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#2144183 - 08/29/17 11:54 PM Re: Take One HMDA Disclosures bOaty
Reg Warrior Offline
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Ask the member to pull out there phone and take a selfie with the post.
Last edited by Reg Warrior; 08/29/17 11:55 PM.
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#2144185 - 08/30/17 02:35 AM Re: Take One HMDA Disclosures bOaty
Kathleen O. Blanchard Offline

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I would take the nontech simple route. give a piece of paper with the web link. I read the statement above that I am to give her something so she does not walk away empty handed. Have some postcards printed. Have pull offs like at the laundromat. Something they can carry home.
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#2144188 - 08/30/17 12:17 PM Re: Take One HMDA Disclosures bOaty
Kathleen O. Blanchard Offline

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Don't forget that the requirement covers several years and the data will be available online beginning one year at a time, so for several years, you will have the old method and the new method combined, until the new method has been around long enough for all required data to be available online.

You can amend the language on the poster and say years xxxxx, available here, years xxxx, available online.

The poster is suggested, not mandatory language and I did ask the CFPB about this.
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#2144194 - 08/30/17 01:29 PM Re: Take One HMDA Disclosures bOaty
waldensouth Offline
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You could also have a policy of obtain the requestor's email address and sending them the notice with live link electronically. That would prevent having those little pieces of paper lying around unused. OR have it in a work document stored on your bank's shared drive where all employees could access it and have them print it out when the customer makes this request.
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#2144220 - 08/30/17 02:39 PM Re: Take One HMDA Disclosures bOaty
Kathleen O. Blanchard Offline

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I like having things on a shared drive for printing as needed, just like the public file for those who have made that switch. My take is that the Bureau wants the person to have something in their hand, just like they would have had a file under the current rule.
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#2144233 - 08/30/17 03:32 PM Re: Take One HMDA Disclosures bOaty
RVFlyboy Offline
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That is our plan - shared drive accessible for printing if requested. Keep in mind, everyone, that if someone comes in asking for your HMDA data, you can be pretty sure they are already operating from a premise that doesn't have YOUR best interests in mind. And you can be pretty sure they are going to have been well-coached on what the institution is required to provide when they ask, so if you don't provide it you're just adding fuel to the fire.
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#2144235 - 08/30/17 03:37 PM Re: Take One HMDA Disclosures bOaty
CompliantOkie Offline
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Agree Beech. I cannot imagine a circumstance where the average consumer will ask to take the disclosure. Likely the disclosure will be requested by a group looking for trouble or an individual posing as a potential customer. Training the LO's will be extremely important!!

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#2144236 - 08/30/17 03:38 PM Re: Take One HMDA Disclosures Kathleen O. Blanchard
MScarn6942 Offline
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Originally Posted By Kathleen B
I like having things on a shared drive for printing as needed, just like the public file for those who have made that switch.


Does that mean we can keep our public file electronically and just print it when someone requests it??
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#2144239 - 08/30/17 03:41 PM Re: Take One HMDA Disclosures bOaty
RR Joker Offline
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That was going to be my suggestion. Surely you already have P&P's out there....just include this as well.

OR have it in a work document stored on your bank's shared drive where all employees could access it and have them print it out when the customer makes this request.
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#2144242 - 08/30/17 03:46 PM Re: Take One HMDA Disclosures bOaty
Truffle Royale Offline

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I have never printed our public file.
If someone were to ever ask, I'd print it at that time, but no one has ever walked in and requested it.
As for those annual 'please send us your LAR' requests from various public service groups, we've always replied with a request to cover printing costs and never heard back.
From Kathleen's post above "My take is that the Bureau wants the person to have something in their hand, just like they would have had a file under the current rule."
I take that to mean we can continue our status quo.

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#2144245 - 08/30/17 03:52 PM Re: Take One HMDA Disclosures bOaty
RR Joker Offline
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TR, we're talking about the notice which would contain the instructions on how to obtain the LAR. Not the LAR, itself.
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#2144249 - 08/30/17 03:56 PM Re: Take One HMDA Disclosures Truffle Royale
Kathleen O. Blanchard Offline

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TR, the LAR will be available on the CFPB website and the process and poster (and notice to walk ins) is changing. Going forward, if you receive an email from someone asking for your LAR, you can direct them to the Bureau's site, for years that are posted there which will not be the prior years.

Bear in mind, everyone who asks for LARs will be well aware of this change.

Also bear in mind that the plan is to make the LAR available by April of each year, not September.
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#2144250 - 08/30/17 03:59 PM Re: Take One HMDA Disclosures bOaty
Kathleen O. Blanchard Offline

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TR, also if you choose to provide you can charge for costs, but who would both to do that for the years under the new rule when you can just direct them to the CFPB website?
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