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Are we required to display the Annual Disclosure Statement, HMDA Disclosure Notice, CRA Notice and Equal Housing Poster at a branch that has only a drive-up facility? The facility is approved as a branch, and there is one teller onsite. – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

Are we required to display the Annual Disclosure Statement, HMDA Disclosure Notice, CRA Notice and Equal Housing Poster at a branch that has only a drive-up facility? The facility is approved as a branch, and there is one teller onsite.

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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)