Annual Disclosure Statement: Yes. You are required to post the Annual Disclosure statement at each branch.

HMDA Data Availability Notice: Maybe. If the drive-up is approved as a branch by a federal or state agency and is located in a Metropolitan Statistical Area or a Metropolitan Division, then you are required to post the HMDA Data Availability Notice.

CRA Notice: Yes. You are required to provide the CRA Notice at each branch. In this context, a “branch” means a “staffed banking facility authorized as a branch” as defined in the FDI Act.

Fair Housing Poster: No. We do not believe you need to display the Equal Housing Opportunity poster if the facility is not engaged in “extending” loans.

For resources related to our guidance, please see below:

• Annual Disclosure Statement Notice — 12 CFR 350.7(b) (“In the lobby of its main office and each branch, the bank shall at all times display a notice that the annual disclosure statement may be obtained from the bank.”)
• HMDA Data Availability Notice — 12 CFR 1003.5(e) (“A financial institution shall post a general notice about the availability of its HMDA data in the lobby of its home office and of each branch office located in an MSA and Metropolitan Division.”)
• CRA Notice — 12 CFR 345.44 (“A bank shall provide in the public lobby of its main office and each of its branches the appropriate public notice set forth in Appendix B of this part”)
• Fair Housing Poster — 12 CFR 338.4(a) (“Each bank engaged in extending loans for the purpose of purchasing, constructing, improving, repairing, or maintaining a dwelling or any loan secured by a dwelling shall conspicuously display” the Equal Housing Lender Poster)