Used to be you have to keep five years of HMDA LAR in your public file. Then they changed it to just having a link to where people can find the LAR.
Might be a silly question, but have you been slowing phasing out that five year retention, or do you now only show the one page that tells them where to go online to find a LAR?

228.43 no longer refers to historical data and the CFPB site has 6 years worth of data there. I see no point in keeping it in the Public File. In my 20+ years I don't need more than one hand to count the times my file was reviewed by other than an examiner. In fact it was 1 or maybe 2 and the one I do remember did it because they were a church and heard it was good to do. They had no idea what they were looking at or why. I see the intent, but it's just an solution looking for a problem to solve.

Agree with Andy. The CFPB site has the historical HMDA. The only people that ever requested my public file were reporters looking to do a hit piece or community advocates looking for a bargaining point.