I am still confused on this HMDA Data in the CRA Public File. I have the Home Mortgage Disclosure Act Notice in the file. My confusion is whether I need to keep 2015 & 2016 HMDA data in my public file. I think originally we had to keep the prior 2 years but everywhere I am reading says if it is on the CFPB's website we no longer have to keep it in our file, however, I cannot find it on the CFPB's website. So in that case how long do I have to keep them in our public files? We are an ISB.

For CRA public file purposes (§ 345.43)
"(2) Banks required to report Home Mortgage Disclosure Act (HMDA) data."

"A bank required to report home mortgage loan data pursuant part 1003 of this title shall include in its public file a written notice that the institution's HMDA Disclosure Statement may be obtained on the Consumer Financial Protection Bureau's (Bureau's) Web site at www. consumerfinance.gov/hmda. In addition, a bank that elected to have the FDIC consider the mortgage lending of an affiliate shall include in its public file the name of the affiliate and a written notice that the affiliate's HMDA Disclosure statement may be obtained at the Bureau's Web site. The bank shall place the written notice(s) in the public file within three business days after receiving notification from the Federal Financial Institutions Examination Council of the availability of the disclosure statement(s)."

The requirement covers the previous two calendar years. So beginning in 2019 the disclosure data for 2017 and 2018 would be required and the statement in your public file should state that it is available at the CFPB website if you are a HMDA reporter.

I haven't bothered checking the CFPB website, but I know there has been a very high number of refilings of the HMDA data due to abnormally large numbers of reporting errors (largely related to the vastly expanded HMDA LAR). I haven't checked to see if they have posted the Disclosure data or delayed it because of the large volume of reporting errors.