You’ve likely heard us say before that “HMDA is an application regulation.” That means that certain information must be collected at the time of application…not when you remember to do it, not at closing…but at application. This includes the applicant(s) demographic information. If you’re auditing your HMDA data for accuracy, this is one area you’ll want to look at since it can be an easy source of potential violations.
David explains more in the video.
All right, page 26. Here's where we're back to the auditors. They are to collect demographic information at the time of application. It's not three days later. It's not at closing. It's not later on. It's right now at that initial request, not complete app. It's that here's only one definition of an application, and letter C, "You must ask for that," it says to them.
Even if it's on the phone, they have to be giving them this disclaimer. If they're taking it over the phone, they're going to read them that disclaimer, verbatim. And then do me a favor. Let's go back to page 33. Let's see. Page 33 will work. You can see the demographic information, the disclaimer, you can see all the boxes there. So, if I'm taking a phone application, I'm going to read them that disclaimer, and I am going to read through, "Is your ethnicity, one, Hispanic or Latino?"
And that includes Mexican, Puerto Rican, and Cuban, other. Now, I don't have to read in the print origin because that's in italics. I don't have to read them the "for example" because that's in italics, but I have to read them all of those choices. So, if you go back to page 26, letter E, it says, "For applications by phone, you must ask or state to the fill out this information except for the information which pertains to the application, taken in writing, indicated in the italics. So, the point is, "You're going to read through this whole thing." Most loan officers are not doing that. So, finding out how they're taking the app and how that's being completed is a big deal.
Published
2022/12/09