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Question & Answer
Question: We sometimes get applications from applicants who are multi-racial. These applicants generally do not want to describe themselves as one race or ethnicity How should they fill out the monitoring information?
Answer: It can be touchy enough to get through the monitoring data collection process without this complication! One principle to follow is that, when describing themselves, the applicant is always right. They way they describe themselves is the way the monitoring data stays. At this point, the best approach to use in this situation is to suggest that the applicant may check "Other" and write in "Multi-racial."
This approach is also appropriate for the loan officer to use if the customer refuses to provide the information and the loan officer must complete it. Observation of multiracial applicants will not always be accurate, but what is important is the loan officer's observation. One word of caution: Using the "Other" category should not be used as an easy substitute for accurate observation. The data should be as accurate as possible. For fair lending and CRA reasons, you do not want to undercount your minority applicants.
Copyright © 1997 Compliance Action. Originally appeared in Compliance Action, Vol. 2, No. 11, 9/97
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