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#630230 - 10/26/06 07:13 PM HMDA & PUBLIC FILE
gunches Offline
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Joined: Dec 2005
Posts: 210
We just received our 2005 HMDA Disclosure Report back from FFIEC. How much of this has to be placed in the public file? I have a HMDA Institution Register Summary, many Disclosure Tables,
Summary Tables, and Supplemental Tables.

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#630231 - 10/26/06 07:46 PM Re: HMDA & PUBLIC FILE
Newbie06 Offline
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Joined: Mar 2006
Posts: 785
I've always place the whole disclosure table in the public file.

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#630232 - 10/26/06 07:47 PM Re: HMDA & PUBLIC FILE
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,886
Bloomington, IN
Quote:

We just received our 2005 HMDA Disclosure Report back from FFIEC. How much of this has to be placed in the public file?




You must make the entire disclosure prepared by the FFIEC available.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#630233 - 10/26/06 08:26 PM Re: HMDA & PUBLIC FILE
MadisonCali Offline
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Joined: Jun 2006
Posts: 2,515
Do you have to have it in all offices or just what you would call your 'main' branch?
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#630234 - 10/26/06 08:28 PM Re: HMDA & PUBLIC FILE
Dan Persfull Offline
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Dan Persfull
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Posts: 47,886
Bloomington, IN
See 304(a)(1) on page E-2 in the GIR.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#630235 - 10/26/06 09:01 PM Re: HMDA & PUBLIC FILE
MadisonCali Offline
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Posts: 2,515
Got it. Thanks, Dan!
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The beatings will continue until morale improves...

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#630236 - 10/27/06 03:18 PM Re: HMDA & PUBLIC FILE
Tater Offline
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Joined: Jan 2006
Posts: 661
Missouri
OK, we submitted data for the first time as of 12/31/05...I found disclosure statements for my institution on the FFIEC website...and read something about that is how they are now provided, not through the mail. So I suppose this is a 2-part clarification question:

1) Do we get a disclosure in the mail? Or do we get it from the website.

2) (If the disclosure is mailed, question 2 is moot) If it comes from the website, there are multiple different reports that are available on my institution. Do I print them all off and put them in a HMDA Public File (can this be part of the CRA public file, or does it need to be unique?) or are there specific reports I need to include and specific reports I need to exclude?

Thanks in advance for your help everyone!
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Opinions are my own and do not reflect any others

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#630237 - 10/27/06 03:32 PM Re: HMDA & PUBLIC FILE
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,886
Bloomington, IN
You will no longer get the disclosures mailed to you. They are provided through their Web site now. The disclosure and all supporting schedules are to be kept in your public file. We maintain ours in our CRA file.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#630238 - 10/27/06 03:34 PM Re: HMDA & PUBLIC FILE
Truffle Royale Offline

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Posts: 17,421
1) As of 2005 report, only available on website.
2) Print out all the reports for your institution and put them in a seperate HMDA public file.

All this information should be available to the public.
I've read that some institutions are copying to CD/DVD's and can print a paper copy if requested. My FI's report was manageable enough to print one hard copy.

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#630239 - 10/27/06 10:09 PM Re: HMDA & PUBLIC FILE
CRAatBOK Offline

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Joined: Mar 2004
Posts: 6,172
Further South than I wanna be.
I downloaded the required reports and burnt them on a CD. We keep it in our public file. I did make one hard copy, just to make the examiners happy.
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Life is not the way it's supposed to be. It's the way it is. The way you cope with it is what makes the difference.

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