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#2150360 - 10/18/17 08:10 PM New Lobby Notice
Reg Booster Offline
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Joined: Aug 2010
Posts: 106
Midwest
Looking at the text, the suggested notices only vary slightly. Does it matter which notice I use?

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#2150631 - 10/20/17 04:12 PM Re: New Lobby Notice Reg Booster
Reg Booster Offline
100 Club
Joined: Aug 2010
Posts: 106
Midwest
bump

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#2150642 - 10/20/17 04:46 PM Re: New Lobby Notice Reg Booster
Compliance NABW Offline
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Joined: Oct 2015
Posts: 1,669
Yes, it matters. The new requirement requires the website reference. This is an important difference.

See 12 CFR 1003.5(b)(2) of the 2018 amended Regulation.
https://www.consumerfinance.gov/eregulations/1003-5/2015-26607_20180101#1003-5-a-2

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#2150644 - 10/20/17 04:52 PM Re: New Lobby Notice Reg Booster
Reg Booster Offline
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Joined: Aug 2010
Posts: 106
Midwest
Right, I know there is a new notice, but the reg gives two versions of the same notice. I am wondering which of the two example notices should be displayed - not whether a new notice is required.

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#2150663 - 10/20/17 06:01 PM Re: New Lobby Notice Reg Booster
Compliance NABW Offline
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Joined: Oct 2015
Posts: 1,669
I guess you are referencing the difference between the suggested notice in (b) and (c) versus the suggested notice in (e). Technically, they are for different reasons. Subpart (e) is specifically for the Lobby Notice, while subparts (b) and (c) are for the notices that must be given upon public requests and when the FFIEC delivers a disclosure statement based on the data submitted for the prior year. Considering that the only difference is a flip of the last two sentences and the Regulatory versions are only "suggested" notices. I would expect that the suggested text of (b) and (c) could be used for all 3 scenarios, but to play it safe you may want to use the specific language of 12 CFR 1003.5(e) Official Commentary #1 for the Lobby Notice.

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