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#2209598 - 03/26/19 08:09 PM Re: CRA Public File change in 2018? rlcarey
ccman Offline
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The HMDA Disclosure Statement for 2017. I found the info on the FFIEC website not CFPB.

Is that correct? If so, how is the notice correct for the Lobby with the CFPB website shown?

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#2209618 - 03/26/19 09:41 PM Re: CRA Public File change in 2018? StormFront
rlcarey Online
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rlcarey
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Galveston, TX
I guess I am confused. Are you referring to the HMDA lobby notice or are we talking about CRA Public files, which is the title of this thread??
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#2209666 - 03/27/19 03:10 PM Re: CRA Public File change in 2018? rlcarey
ccman Offline
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I'm referring to what's in the Public File. According to the rule, if the data is not on the CFPBs website then we must
keep a hard copy of the HMDA Disclosure Statement in our Public File for the past two years.

Is that correct? The CFPB does not have our HMDA data for 2017 nor 2016 on its website?

I'm confused as well!!

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#2209785 - 03/28/19 04:16 PM Re: CRA Public File change in 2018? StormFront
Tennismom Offline
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View this link: https://ffiec.cfpb.gov/data-publication/ for 2017, indicating that their site only houses data and reports for HMDA data collected in or after 2017. For HMDA data and reports for prior years, visit https://www.ffiec.gov/hmda/hmdaproducts.htm.

At one point in time I and other BOLers were able to pull up prior year's LARs on the CFPB site. Not sure why they changed it.

I get what you are saying ccman. A bank posts the new Home Mortgage Disclosure Act Notice in your lobby which includes the text: "These data are available online at the Consumer Financial Protection Bureau’s website (www.consumerfinance.gov/hmda)." when in fact, only one year is available on their site.

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#2209932 - 03/29/19 10:11 PM Re: CRA Public File change in 2018? StormFront
mrogersfib Offline
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I actually went to go put the CFPB notice in our lobby notice, and asked our examiner before hand about it. They instructed us to keep it as it were before hand, and maintain 2 years of HMDA data on hand vs what CFR says. It had to of been related to what you are saying that only one year is kept on file at the CFPB now. I would say if your exam cycle is completed and all your HMDA data can be found on the CFPBs site then you should be fine--I would keep a copy on hand just incase.

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#2249506 - 02/22/21 03:44 PM Re: CRA Public File change in 2018? StormFront
TeamComply Online
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Previous quote from Adam Witmer (from 2017), is this still the case regarding the CRA public file requirements for an Intermediate Small Bank:

"An intermediate small bank (ISB) is still a small bank by definition, so the public files rules are the same for an ISB and those that are not and ISB."

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#2249508 - 02/22/21 03:48 PM Re: CRA Public File change in 2018? StormFront
Adam Witmer Offline
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Notwithstanding the OCC changes to CRA rules, yes, an ISB is still a small bank by definition.
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