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!