If you allow applicants to complete/submit HMDA applications online, you must give them the opportunity to complete their Demographic Information (DI). You must also allow them to leave it blank, if they so choose. If the application is also subject to the TRID requirements, you are prohibited from requiring anything beyond the six pieces of information for a TRID application (none of which are DI). If the applicant “slams the door” by marking “I do not wish to provide…”, you are done and should not collect DI. If they don’t mark anything and leave it completely blank, you “may” need to collect it later on, depending on the circumstances. We receive questions like the following quite often, and the answer isn’t as simple as it may seem:
If you get an online application and the demographic information isn't provided at all, is the lender allowed to call and ask them if they missed it or they just chose not to provide it?
David explains more in the video.