Skip to content
BOL Conferences
Thread Options
#2168634 - 03/16/18 04:03 PM CRA Public Files for HMDA Reporters
Indy Banker Offline
Platinum Poster
Joined: Aug 2010
Posts: 528
Confused about the CRA public file requirements under the 2018 rules - does someone have a checklist that a HMDA-reporting ISB would use for Main Office and Branch Office CRA public files?

Return to Top
CRA
#2168637 - 03/16/18 04:12 PM Re: CRA Public Files for HMDA Reporters Indy Banker
Sunshine Lady Offline
Platinum Poster
Sunshine Lady
Joined: Apr 2014
Posts: 680
• Written comments received from the public that specifically relate to the bank’s CRA performance and any response to the comments by the bank.
• CRA performance evaluation.
• Banking Center information, including:
List of Banking Centers with their street addresses and geography’s
List of Banking Centers opened or closed
List of services generally offered, and cost of services.
• A map of our assessment area, showing boundaries of the area and identifying the geography’s contained within the area.
• The bank’s HMDA Disclosure Statement.
• The bank’s Loan to Deposit ratio.
_________________________
Define Success on your own terms, achieve it by your own rules, and build a life you are proud of. Anne Sweeney

Return to Top
#2168686 - 03/16/18 05:53 PM Re: CRA Public Files for HMDA Reporters Indy Banker
Indy Banker Offline
Platinum Poster
Joined: Aug 2010
Posts: 528
Thanks Sunshine Lady - specifically I'm looking for the new requirements as it relates to whether we still have to keep copies of prior years' modified LAR's, and past years' Disclosure Statements in the Main Office public file or does the Notice of its availability on the CFPB website suffice now? And does that notice (the hard copy "hand out") have to be available in each branch public file or just the Main office?

Return to Top
#2168804 - 03/16/18 08:57 PM Re: CRA Public Files for HMDA Reporters Indy Banker
RR Jen Offline
Power Poster
RR Jen
Joined: May 2003
Posts: 3,760
Running and riding everywhere ...
Check out this section of the regulation and the amendment. I'm not keeping prior copies or Disclosure Statements. My public file is electronic on our intranet and the same for all locations, but this is an easy one that wouldn't hurt to be in your branch copies.

https://www.bankersonline.com/regulations/12-228-043

Editor's Note:
Effective January 1, 2018, paragraph (b)(2) is revised to read:
(2) Banks required to report Home Mortgage Disclosure Act (HMDA) data. A bank required to report home mortgage loan data pursuant part 1003 of this title shall include in its public file a written notice that the institution’s HMDA Disclosure Statement may be obtained on the Consumer Financial Protection Bureau’s (Bureau’s) website at www.consumerfinance.gov/hmda. In addition, a bank that elected to have the Board consider the mortgage lending of an affiliate shall include in its public file the name of the affiliate and a written notice that the affiliate’s HMDA Disclosure Statement may be obtained at the Bureau’s website. The bank shall place the written notice(s) in the public file within three business days after receiving notification from the Federal Financial Institutions Examination Council of the availability of the disclosure statement(s).
_________________________
I don't need any more negativity in my life...be positive and helpful people or I will kick you in the shins!!!

Return to Top