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Yes Jack, We will also be exempt for 2018 based on our 2 year look back.
I do have my 2015 and 2016 LAR data and HMDA Disclosures available.
I also had to totally redo my HMDA Policy to reflect the changes.
Below is what I came up with for my lobby notice. Should I take out the top paragraph?
HOME MORTGAGE DISCLOSURE ACT NOTICE
The HMDA data about our residential mortgage lending are available for review. The data show demographic distribution of loans and applications, race, gender and income of applicants and borrowers; and information about loan approvals and denials. You are hereby notified that copies of our HMDA statement and a modified loan application register data filed with the FFIEC are available for your inspection upon written request at our office located at 206 W. Broadway Blvd, Jefferson City, TN 37760.
January 1, 2018
When applicable for First Peoples Bank of Tennessee, the HMDA data about our residential mortgage lending will be available online for review. The data show geographic distribution of loans and applications; ethnicity, race, sex, age, and income of applicants and borrowers; and information about loan approvals and denials.
HMDA data for many other financial institutions are also available online. For more information, visit the Consumer Financial Protection Bureau’s website (www.consumerfinance.gov/hmda)
Contact: Trish Bowman
First Peoples Bank of Tennessee