Anyone else notice the FFIEC has yet to publish the 2017 CRA Disclosure statements? I'm trying to update our public file and this is the last thing to get done before April 1st.

Is there a rule change on what's required I am not aware of? Or is the FFIEC a little late this year?

The data for 2016 was not released until November 2017.
The data for 2015 was not released until August 2016.

It was just filed March 1, was it not?

I thought it was sufficient to provide a written notice containing the link to the CFPB website to the consumer so they can obtain the Disclosure statements.....do we still have to put the entire disclosure statements in our public file?

Tennismom - yes, those links confirmed my understanding of the new requirements, but doesn't explain why the OP is waiting for the CFPB to publish 2017 Disclosure Statements to update their public file....?

It's my understanding that while the requirements for the HMDA disclosure statements have changed, the CRA disclosure statements have not. I'm planning to put (digital) copies of my CRA disclosure statements in my public file this fall.

Ok thanks Jen for clearing that up for me - yes I was confusing the HMDA disclosure statement with the CRA disclosure statement...... ugh....

Yeah CRA is still under the FFIEC, HMDA is now under the CFPB

But the government is known for it's speed and consistency in delivering results right?

So we should still put paper CRA Disclosure Reports in our CRA Public files?

For the HMDA data, I added a notice with our HMDA reports that the 2017 data may be obtained on the CFPB (spelled out) website and provided the address. I left in the prior year paper reports. Is this what other institutions are doing?

Yes, you will still put the paper CRA Disclosures in your file, but for HMDA, you'll put the actual notice that states that the disclosure statements are available on the CFPB's website. This notice must be added to your Public File no later than 3 business days after receiving notice from the FFIEC. The retention is the same as the actual disclosure statements (5 years). You'll want to check the website to see if the prior two years are now showing available for your institution and, if so, you can actually remove those from the Public File as well.