I'm a little late jumping on this thread, so one thing I saw about this new 2018 notice is that it adds "age" of applicants and borrowers. Not something that was a data point pre 2018.
So if we post this notice now and someone does go look up our data, age will not be there until we submit our 2018 data in 2019.
Any thoughts?

Post the notice. Submit your data. If someone asks why your notice mentions age and the data doesn't provide it (which I doubt), you can explain this is a new requirement and will be coming in future years.

Thank you David. We have never even had someone from the general public ask for our data. I just find it interesting that they would put age, when its not going to be on there until the next year. I tend to overthink things.

Since it's April 2, I'm updating my CRA Public File and removing two years of HMDA Disclosure Statements, replacing them with the Notice. If anyone requests this information, I will instruct the branches to print and provide the Notice. However, do I leave two years of CRA Disclosure Statements??

I know this is an old thread but I am in the middle of tightening up the Bank HMDA Policy and need some direction. Just a couple things maybe someone can help me out with.

1003.5(b) states the Bank must put out this notice 3 days after receiving notice from the FFIEC that the modified LAR is ready.

1- Notification came from the CFPB about the LAR being ready. Is this still be completed by the FFIEC or the CFPB.
2- Since we have 3 days from receiving the notification, do we need to add the year the data is available for to the notice? Or can we use the same notice using the general terminology since the changes became effective? Common sense tells me that adding the year would be best. 2017 Data is now available, 2018 now available.

Let me know how your institution is doing this and/or if I am missing something. Thank you.

No later than three business days after receiving notice from the FFIEC that a financial institution's disclosure statement is available, the financial institution shall make available to the public upon request at its home office, and each branch office physically located in each MSA and each MD, a written notice that clearly conveys that the institution's disclosure statement may be obtained on the Bureau's Web site at www.consumerfinance.gov/hmda

What this says is that you must make the disclosure statement available upon request within 3 business days. You don't put a notice out. You always have a notice up in your lobby. Refer to .5(e) for the lobby notice requirements:
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. An institution shall provide promptly upon request the location of the institution's offices where the statement is available for inspection and copying, or it may include the location in the lobby notice.

Right ,the notice that we issue to the person requesting it. The Bank needs to have an updated notice 3 days after being notified by the FFIEC. There is also a requirement that we keep this notice for 3 years. So while the regulation doesn't say it that I can see, we should update the notice accordingly each year that we would issue to the person requesting it.

For example. The 2017 HMDA data about our residential mortgage lending.......

If we do not put a date on it, how do we prove we retained a copy for 3 years?

Am I missing something? Sorry if I wasn't clear originally.

I'm curious as well, as we were notified today by the FFIEC,

Bump. This is something that has just recently been brought to light as we are being told that we must retain the Disclosure statement referenced in 1003.5(b) that is provided by the FFIEC. I thought we were good by posting the HMDA notice in our branches (1003.5(e)), but this appears to be a different statement.

Am I correct in thinking that this is something that we SHOULD retain and make available upon request in addition to the notice required by 1003.5(e) and posted in our lobbies?

Ask them for a citation that says you need to retain a copy of the notices that you used over the last three years.

In reference to the 1003.5(b) disclosure statement each of our branches has the disclosure in a Word document they can print and provide to the consumer if requested. Some of the branches keep printed copies in their Branch CRA File. I keep a printed copy in our CRA File maintained at the Main office.

Under the 2018 revisions there is no longer a retention requirement for the HMDA data provided by the CFPB. You simply have to provide the 1003.5(b) disclosure to the consumer upon request. That notice also satisfies 1003.5(c).