Skip to content
BOL Conferences
Thread Options
#2191628 - 09/05/18 01:53 PM HMDA POSTER FOR A NON-HMDA INSTITUTION
compliance75 Offline
100 Club
Joined: Oct 2016
Posts: 105
In our previous life we were covered by HMDA. Since the new rules came out we are no longer covered but we have continued to have a HMDA poster to address information that was reported in previous years.
Is there a new requirement for a HMDA Poster for non hmda-institutions?
How long do we need to keep the old poster?
Thank you

Return to Top
HMDA

   
HMDA Academy
#2191656 - 09/05/18 04:27 PM Re: HMDA POSTER FOR A NON-HMDA INSTITUTION compliance75
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
There is no poster for non-HMDA institutions. The regulation doesn't apply to you any longer, so you can take it down (you could have taken it down 1/1/18).
_________________________
David Dickinson
http://www.bankerscompliance.com

Return to Top
#2191757 - 09/06/18 02:22 PM Re: HMDA POSTER FOR A NON-HMDA INSTITUTION compliance75
compliance75 Offline
100 Club
Joined: Oct 2016
Posts: 105
Awesome, will it hurt to continue showing it?

Return to Top
#2191782 - 09/06/18 03:31 PM Re: HMDA POSTER FOR A NON-HMDA INSTITUTION compliance75
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,658
I would take it down if possible as the poster you have up is going to be the old model form which would be low hanging fruit for an auditor.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top
#2191785 - 09/06/18 03:33 PM Re: HMDA POSTER FOR A NON-HMDA INSTITUTION compliance75
LiveFunLife Offline
Member
Joined: Dec 2017
Posts: 91
I just had a post recently where I was informed that if you are not doing something do not leave traces of it around. If you are non-HMDA you should not leave up HMDA material. If it isn't required do not do it. You know it won't hurt you to remove it but you don't know if it will hurt you if you leave it up.

Still if one of the BOL regulars say differently they may know just a bit more than I do smile

Edit* Didn't refresh as I was reading other posts and Adam totally beat me to the punch!!!
Last edited by LiveFunLife; 09/06/18 03:34 PM.
Return to Top
#2191818 - 09/06/18 04:53 PM Re: HMDA POSTER FOR A NON-HMDA INSTITUTION compliance75
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Quote:
if you are not doing something do not leave traces of it around

Great point!

I agree to take it down - as I said in my first post. There's no benefit (or requirement) to leave it up. There is risk to having it up.
_________________________
David Dickinson
http://www.bankerscompliance.com

Return to Top
#2191825 - 09/06/18 05:03 PM Re: HMDA POSTER FOR A NON-HMDA INSTITUTION compliance75
compliance75 Offline
100 Club
Joined: Oct 2016
Posts: 105
Sounds like a plan, thank you so much!

Return to Top