We qualify for the low-volume lender exclusion from reporting 2017 and 2018 activity.

We filed our 2016 activity in 2017. We have filed for many prior years.

We are a state-chartered, non-Federal Reserve member bank and the FDIC is our federal regulator.

Do we need to notify anyone such as FFIEC, CFPB, FDIC, or other that we will not be filing anything in 2018 for 2017 activity?

There is (so far) no requirement for notification. If you are below the closed end minimums, it will be obvious from your 2015 and 2016 LARs that you are not at the threshold.

Yes, we have determined that we are below the threshold for 2015 and 2016.

Will the CFPB have years prior to 2017 available on their website?

If they won't, and we have no reported items for 2017, then I wonder if we would still need to provide the new sample combination notice upon request and update the lobby notice?

When I asked about prior data a while back (about a year) and the need for posters for both old and new I was told that it did make sense to either have one poster that incorporates both (current method and new CFPB method for new data). That leads me to say that unless things have changed, only 2017 will be online at first.

Because HMDA requires data to be available for several years (disclosure and LAR), I would keep the sign and the data available until the time period for your data through 2016 runs out.

Thanks!

Ok, we are definitely a low volume bank. However, we have a SMALL branch in an MSA. Does this help us at all , or are we still a reporter because of the MSA branch location?

4newt: You must have an office in a MSA, be over the asset threshold AND meet the volume test to be subject to HMDA.

crc: My opinion: If you are no longer subject to HMDA, I don't believe you need to have a lobby poster displayed any longer. The reg doesn't say "IF you used to be subject to HMDA . . . you must display a poster." It says "IF you are subject to HMDA, you must display a poster." I would certainly keep the data, but I don't think you need to keep the poster. You could certainly leave it up, but it's not required.

Thank you for your answer. I just found my chart! I'll try to remember I have it.

Thanks, David!