Be sure to JOIN US for our webinar, “HMDA Demographic Information Collection”.
You’ve maybe heard us say before that “HMDA is an application regulation”. This means there are certain things you need to do and/or consider at the time of application. One of those things is collecting an applicant’s demographic information. So, whether you see the applicant face-to-face, they submit an application online or you take an application over the phone, they must be given the opportunity to provide their demographic information at the time of application.
David explains more in the video.
Transcript:
Do me a favor, in letter B, page 3, "You must report the data at the time of ..." put a little caret, "initial application," not complete, "initial." That's the big deal here.
Now, you could sit there at your computer, and you can say, "Tell me what you are," in that report. But you'd have to read them that entire disclaimer that you see in box D, or upon your screen right now. So I think it's safer just to hand it to them, have them fill it out. Or maybe it's over the internet or things like that. But if you're taking a phone application, look at letter E, you're going to do this at that time of the initial application. And that means that you're going to be reading them this disclaimer that you see there on page D.
Now, just go back to page 10 with me for a minute, page 10. You'll see there is basically a Fannie Mae 1003, at the bottom of it. And you're going to have that same disclaimer. And then you're going to have to read to them all of the options. The only thing you don't have to read to them is anything in italics, and that would be where there's a text field.
So look at Hispanic underneath ethnicity, Hispanic. Then drop down to Other. And then it says, "For example, Argentinian, Colombian, Dominican," you don't have to read them that. But you have to give them all of these choices. So when you come to Hispanic-Latino, then you might say, "For instance, Mexican, Puerto Rican, Cuban, or Other," and you're going to have to read all those.
Go over to the race side. You don't have to give them the Other Asian for example and the other Pacific Islanders or Native Hawaiian. That's it though. You're going to read them everything else which, to me, is pretty confusing and difficult to do. But if you're taking a telephone app, you're going to have to do that.
So I'm just going to reemphasize here on page 3, you have to be asking them for this information. You have to give them the disclaimer. And you have to do it at the initial application, even if that's over the phone.