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What are the Home Mortgage Disclosure Act (HMDA) lobby signage requirements for a bank located in a metropolitan statistical area (MSA) but not required to report because it did not originate enough covered loans?

The bank is not obligated to post the HMDA notice under these circumstances. Section 1003.5(e) of Regulation C provides that a “financial institution” must post the HMDA notice in the home office and each branch located within a MSA (or metropolitan division). The term “financial institution” is limited to institutions that originated at least 25 non-excluded closed-end mortgage loans and at least 500 non-excluded open-end lines of credit in each of the two preceding calendar years. Therefore, if a bank does not meet the definition of “financial institution” due, for example, to the origination test, it is not required to post the notice. However, it appears that there is no prohibition against posting the HMDA notice even though it is not technically required. (November 2018)

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