Are we required to disclose in our branches what was submitted for HMDA/CRA by 3/31 BEFORE we receive anything from the FFIEC? I'm confused by what the reg. and HMDA guide say. Thanks.

What I understood is we put a modified LAR in the public file and it remains until we receive our HMDA Disclosure Statement which will probably be towards the end of the summer. We still have to have each year's modified LAR available to the public for a period of 3 years.

You're required to provide the modified LAR within 30 days of a request.

"Under the revised HMDA regulations a bank must make a modified version of the LAR in electronic or printed format available by March 31, for requests received before March 1, and within 30 days of receipt of a request thereafter. The modifications require the expurgation of the application or loan number, the date the application was received and the date action was taken. No other information can be deleted. "

Len posted that in the BOL guru section. It does not say you have to print it and send it out at all, just that it has to be provided in 30 days IF someone asks for it. I certainly wouldn't bog down the file with documents that aren't required. It confuses the public who want to see the information (holding several years of both the modified and the real LAR) and takes up valuable space.

Thanks Dawn, that makes it much clearer. So if I understand you correctly, if a customer requests it I have 30 days to produce it, and when I receive the report from the FFIEC I then put that out there for inspection. Thanks again.

Thank Len I was cutting and pasting But yes, that's the gist of it.

Oh and just an aside. We're talking the LAR (HMDA). The CRA LR (Loan Register as opposed to Loan Application Register) does not have these requirements. When you get it from the feds in CD format, throw it in the CRA Public File. (Has to be done by September 15th) I print one copy from the disk and keep it in the public file, seperate from both the HMDA and CRA discs, just so they won't be lost. It's easier if someone comes in to look at the file than handing them a disk to play with