Section 1002.107(c)(1) states, …a covered financial institution shall maintain procedures to collect applicant-provided data…and shall otherwise maintain procedures to collect such data at a time and in a manner that are reasonably designed to obtain a response. The Commentary provides examples of procedures that would be and those that would not be reasonably designed to obtain a response. For example, …the earlier in the application process the financial institution initially seeks to collect applicant-provided data, the more likely the timing of collection is reasonably designed to obtain a response. On the other hand, …if a financial institution’s stated procedure is to collect applicant-provided data on or with a paper application form, but employees encourage applicants to skip the page that asks whether the applicant is a minority-owned business or a women-owned business…, the financial institution’s procedures are not reasonably designed to obtain a response.
Published 2026/09/17
