HMDA Demographic Information & Applications Not Taken In Person

When an applicant submits a HMDA-reportable application, institutions are required to request demographic information (i.e., ethnicity, race, sex). The applicant(s) is not required to provide their demographic information and the collection form accommodates this option with an “I do not wish to provide this information” box. How a lender proceeds largely depends on how the application was received. In the case of applications that are not taken in person (mail, phone, internet, etc.), you could run into a couple of different scenarios.

  1. The applicant marks the “I do not wish” box (or confirms this orally on a phone application).

In this case, the applicant has slammed the door and you have no further obligation to request and/or obtain their demographic information.

  1. The applicant does not mark the “I do not wish box” and leaves the demographic information blank.

In this case, the applicant has left the door open. This means that if you see the applicant in person before loan closing, you must request the applicant’s demographic information again. If they confirm they do not wish to provide the information at that time, the lender must collect it based on visual observation or surname.

David explains more in the video.

 

HMDA Resources!

Published
2024/02/20

 

David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

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