One of the greatest areas of confusion when it comes to collecting Demographic Information (DI) are the three little “yes/no” boxes that ask: How did you collect this information? Was it completed by the loan officer or not? When you have a face-to-face application and the applicant marks, “I do not wish to provide this information”, the loan officer is going to complete the ethnicity, race and sex based on visual observation. They will then answer those questions, “yes, yes, yes”, to show that they collected it.
The confusion arises when an application is not taken in person (phone, internet, mail, etc.). If the applicant marks, “I do not wish …”, how should the lender answer those three “yes/no” boxes? The answer lies in the Filing Instruction Guide, which the CFPB has told us on several occasions is the ultimate authority.
Check out the video as Dave explains this in greater detail.
This is exactly the kind of thing we will cover in our “HMDA Demographic Information Collection” webinar on March 7, 2019. We will get into the weeds and talk about when you do have to collect this information and how to collect it. We’ll look at the sub-categories, how to report it and more. Register today and get your questions about Demographic Information answered. See you soon!