HMDA Demographic Information at Application
If you’ve followed us for long, you’ve likely heard us say “HMDA is an application regulation”. The point we are trying to drive home is that lenders need to know at the time they receive an application whether it’s a HMDA reportable application or not. One of the primary reasons is that the applicant’s demographic information (race, sex, ethnicity) must be collected at the time of application. HMDA doesn’t give you a lot of grace so if you collect demographic information when you shouldn’t or don’t collect it when you should, it’s a violation. There are a lot of rules for collecting demographic information and they often depend on how an application is received (by mail, by phone, in person, online, etc.). For example, in all cases the following disclaimer must be provided to the applicant before they provide their demographic information. If the application is taken by phone, that means the lender must read the disclaimer to the applicant before requesting their demographic information.
The purpose of collecting this information is to help ensure that all applicants are treated fairly and that the housing needs of communities and neighborhoods are being fulfilled. For residential mortgage lending, Federal law requires that we ask applicants for their demographic information (ethnicity, race and sex) in order to monitor our compliance with equal credit opportunity, fair housing and home mortgage disclosure laws. You are not required to provide this information, but are encouraged to do so. You may select one or more designations for “ethnicity” and one or more designations for “Race”. The Law provides that we may not discriminate on the basis of this information, or on whether you choose to provide it. However, if you choose not to provide the information and you have made this application in person, Federal regulations require us to note your ethnicity, race and sex on the basis of visual observation or surname. If you do not wish to provide some or all of this information please check below.
David explains more in the video.
2025/02/24
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.