I was wandering if the HMDA Lobby Notice is required for a bank that opened February 12, 2007? We will not be HMDA reporting eligble until January 1, 2009.

Is the FDIC Part 350.7(b), Availability of Financial Information Lobby notice required?

I worked with an established bank before but moved to a DeNovo bank this Monday and I am unsure what impact being a DeNovo has. I do not think a HMDA lobby notice is needed because we do not collect HMDA data yet.