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.

2. 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.

Published
2024/02/20