I just want to make sure that I am understanding this correctly. We are regulated by the FDIC and are an ISB. Since the FDIC rescinded the annual disclosure statement requirement and we no longer need to provide 2017 & 2018 Annual Disclosure Statements in our public files we also DO NOT need to have the notice about the annual disclosure statement in our lobby right?

Bump!

My understanding is that you no longer need it in your lobby. But the CRA requirement is that small banks must include loan-to-deposit ratios for each quarter of the prior calendar year and large banks include the CRA disclosure statement from the FFIEC.

Well, the FDIC "rescinded and removed" part 350. The lobby disclosure was found in 350.7. Therefore, the lobby disclosure requirement has been rescinded and removed, meaning that it is no longer a requirement.

The next logical question is this: must a bank remove the lobby disclosure?

While it may be considered acceptable to leave the disclosure up in 2019 (as I assume all financial institutions had prepared their annual disclosure statement before the FDIC announced the rescission of the rule - and thus have the annual disclosure available), it could become problematic to leave it up in 2020 as financial institutions would be disclosing something that is (presumably) not available (assuming most financial institutions will cease to create the annual disclosure that was required by Part 350).

I am not sure but it seems to me you may be confusing the disclosure statements under HMDA with those under CRA. Only institutions that file their annual CRA data will have a disclosure statement for CRA activity. Since your institution is an ISB you don't have to file your annual CRA data and won't have a disclosure statement unless you voluntarily filed your CRA data (which we always recommend) in which case you would have to download your disclosure statement from the FFIEC website and place it in your public file