Section 1071: Collecting Sex/Gender
When it comes to collecting demographic information under Section 1071, things may look a little different than what you are currently accustomed to. In this case, we’re referring specifically to collecting a principal owner’s sex/gender. Now, you’re likely already doing this under Regulation B and maybe even under HMDA, however, under those two Regulations, when collecting “sex”, the provided forms give options for male or female. HMDA goes a step further to say that, if someone wants to mark both, that is acceptable. Section 1071’s sample collection form, on the other hand, doesn’t give options and, in fact, the Rule requires a free form text field be used for the principal owner to write in their sex/gender rather than just marking a box or boxes.
The Final Rule states, …the Bureau believes that an approach that allows principal owners to designate their sex/gender with the ability to write-in or provide additional information (such as in a free-form field on a paper or electronic form) will encourage applicant self- identification using terminology that may change over time.
Published
2025/01/30
Diane Dean
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients. Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!