COMPLIANCE HOT TOPIC HMDA Notice Requirements QUESTION: We are a mortgage lender. With the new HMDA changes, are we still required to display the HMDA poster in our offices?
ANSWER: Under the old HMDA rules (loans dispositioned prior to 1/1/18), HMDA reporters were required to post a general notice about the availability of their HMDA data in the lobby of their home office and each branch office located in a metropolitan statistical area (MSA). The content of this notice requirement changed with the implementation of the new HMDA rules. Under the new rules, the FFIEC will notify HMDA filers that its disclosure statement (based on data submitted for the prior calendar year) is available. No later than three (3) business days (any calendar day other than a Saturday, Sunday, or legal public holiday) after receiving this notice from the FFIEC, HMDA filers must make available to the public, upon request, a notice that clearly conveys that its disclosure statement and loan/application register, as modified by the CFPB to protect applicant and borrower privacy, may be obtained on the CFPB’s website at www.consumerfinance.gov/hmda. The notice may be in paper or electronic form and must be provided at a mortgage lender’s home office and each branch office physically located in each MSA and each metropolitan division (MD). The CFPB provided sample posted notice language, which may be used to satisfy the new requirements: |
