We’ve seen many banks struggling with how to report Demographic Information for applications not submitted in person (mail, internet, or phone). If an applicant marks, “I do not wish to provide”, you’re done and would then report “Information not provided (mail, internet or phone)” on your HMDA-LAR. If they leave their ethnicity, race and sex blank; however, you must request the information again if you see them during the application process. Since the applicant didn’t tell you “no” initially, you have a requirement to make a request for their information if you see them later in person. If they then indicate, “I do not wish to provide,” you would still be required to collect it based on visual observation.
How are you coming along with collecting the new demographic information? Need clarification, a little refresher or some tips? Be sure to join us for our HMDA Demographic Information Collection webinar on April 26, 2018!
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 transform 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 3 adult children and 2 grandsons (none of whom live at home!) and 3 cats (of which Dave is allergic … the cats, not the children!). They live on a lake in Nebraska and when possible he can be found fishing or making sawdust in his shop. David plays the guitar & piano and enjoys singing with Karen. They occasionally lead worship at their church.