Non HMDA Reporter Bank Disclosure Notice for Lobby

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• January 31, 2018 at 9:01 am EST #12507
  Trish Bowman

  Member

  Any ideas on how I should proceed with my Home Mortgage Disclosure Notice for my bank’s lobby and branches. We are not subject to reporting our 2017 HMDA data.

  I have researched and any help would be appreciated.

  Thank you,

  Trish

  February 4, 2018 at 8:12 pm EST #12525
  jholzknecht

  Keymaster

  Trish,

  I remember you were exempt for 2017. Is your bank covered or exempt for 2018?

  In any event you should have your 2015 and 2016 LAR data and HMDA Disclosures available.

  Use the new HMDA lobby notice. The old data doesn’t seem to be fully available on the CFPB website yet, so make the actual disclosure available upon request.

  Jack

  February 7, 2018 at 8:26 am EST #12533
  Trish Bowman

  Member

  Yes Jack, We will also be exempt for 2018 based on our 2 year look back.

  I do have my 2015 and 2016 LAR data and HMDA Disclosures available.

  I also had to totally redo my HMDA Policy to reflect the changes.

  Below is what I came up with for my lobby notice. Should I take out the top paragraph?

  HOME MORTGAGE DISCLOSURE ACT NOTICE

  The HMDA data about our residential mortgage lending are available for review. The data show demographic distribution of loans and applications, race, gender and income of applicants and borrowers; and information about loan approvals and denials. You are hereby notified that copies of our HMDA statement and a modified loan application register data filed with the FFIEC are available for your inspection upon written request at our office located at 206 W. Broadway Blvd, Jefferson City, TN 37760.

  January 1, 2018

  When applicable for First Peoples Bank of Tennessee, the HMDA data about our residential mortgage lending will be available online for review. The data show geographic distribution of loans and applications; ethnicity, race, sex, age, and income of applicants and borrowers; and information about loan approvals and denials.

  HMDA data for many other financial institutions are also available online. For more information, visit the Consumer Financial Protection Bureau’s website (www.consumerfinance.gov/hmda)

  Contact: Trish Bowman
  Compliance Officer
  First Peoples Bank of Tennessee

  February 9, 2018 at 5:06 pm EST #12560
  jholzknecht

  Keymaster

  You are no longer required to make the actual data available, but until such time as the CFPB has it all available on their website it makes sense to continue to make it available from you. If you are making the data available I would continue to mention the availability in your lobby notice.

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