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!
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.