What HMDA disclosure requirements are being adjusted?

Compliance > Regulation C - HMDA > 2018 Provisions
Q:  What HMDA disclosure requirements are being adjusted?
 
A:  Effective January 1, 2018:
 
MODIFIED LAR
 
Effective January 1, 2018, the 2015 HMDA Rule changes a Financial Institution’s obligations with respect to disclosing its modified LAR. The new requirements apply to data collected in 2017 and later years.
 
Beginning in 2018, upon request from a member of the public, a Financial Institution must provide a written notice regarding the availability of its modified LAR. The written notice must clearly convey that the Financial Institution’s LAR, as modified by the Bureau to protect borrower and applicant privacy, may be obtained on the Bureau’s website at www.consumerfinance.gov/hmda. 12 CFR 1003.5(c).
 
A Financial Institution may, but is not required to, use the sample notice in Attachment C to satisfy the 2015 HMDA Rule’s modified LAR requirement. Comment 5(c)-2. A Financial Institution may, but is not required to, use the same notice for purposes of this disclosure requirement and the disclosure statement requirement discussed in Section 6.3.1. The notice may be made available in paper or electronic form. Comment 5(c)-1.
 
The notice must be made available in the calendar year following the calendar year for which the Financial Institution collected data. The notice must be made available for three years. 12 CFR 1003.5(d)(1). For example, in calendar year 2021, an institution must make available a notice that its modified LAR is available on the Bureau’s website if it was required to collect data in 2018, 2019, or 2020.
 
At its discretion, a Financial Institution may also provide its LAR, as modified by the Bureau, and impose a reasonable fee for any costs incurred to reproduce or provide the data. 12 CFR 1003.5(d)(2). Even if it decides to provide the modified LAR, a Financial Institution must comply with the notice requirement.
 
POSTED NOTICES
 
The 2015 HMDA Rule modifies Regulation C’s posting requirement. Beginning January 1, 2018, a Financial Institution must post, in the lobby of its home office and each Branch Office physically located in an MSA or MD, a general notice about the availability of its HMDA data on the Bureau’s website. 12 CFR 1003.5(e). A Financial Institution may, but is not required to, use the sample notice in Attachment C to satisfy this requirement. In any case, the notice must clearly convey that the Financial Institution’s HMDA data are available on the Bureau’s website at www.consumerfinance.gov/hmda. Comment 5(e).
 
 
ADDITIONAL INFORMATION:
This information was obtained from the CFPB’s Home Mortgage disclosure (Regulation C) Small Entity Compliance Guide.  https://s3.amazonaws.com/files.consumerfinance.gov/f/documents/201512_cfpb_hmda_small-entity-compliance-guide.pdf
 

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