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#141213 - 12/18/03 04:45 PM HMDA / GMI on the 1003
Anonymous
Unregistered

For loan applicants we are now collecting three different data elements, race, ethnicity, and sex. What happens when a borrower furnishes one, or two of these, but not all? (on a telephone/ mail/ internet app) The FNMA/FHLMC 1003 only has one check box to indicate that the information wasn't supplied. It is an "all or nothing" choice? However, the LAR allows the reporter to select "information not provided" on each data element. Can't I just report the ethnicity if this is all that is supplied? Doesn't this form look misleading if that is the case.

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Lending Compliance
#141214 - 12/18/03 04:56 PM Re: HMDA / GMI on the 1003
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
You report what the applicant provides and not provided for what they don't in non face to face applications. For face to face applications you fill in the blanks not provided by the applicant.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#141215 - 12/18/03 08:11 PM Re: HMDA / GMI on the 1003
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,763
Central City, NE
Dan is right. "Info not provided" can only be used for applications received by mail or telephone application after the loan officer requests the GMI, but the applicant refuses to supply.
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David Dickinson
http://www.bankerscompliance.com

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#141216 - 12/29/03 10:53 PM Re: HMDA / GMI on the 1003
Tillie Offline
Gold Star
Tillie
Joined: Apr 2003
Posts: 266
So it would be wrong if the applicant marks "I do not wish" on a face to face interview and then the lender completes upon visual observation/surname? If so, I need to reverse my training.

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#141217 - 12/30/03 02:02 PM Re: HMDA / GMI on the 1003
Bartman Offline
Diamond Poster
Bartman
Joined: Oct 2000
Posts: 1,191
Springfield
Quote:

So it would be wrong if the applicant marks "I do not wish" on a face to face interview and then the lender completes upon visual observation/surname? If so, I need to reverse my training.




No, you have it right. On face to face, applicant can choose not to provide - then you have to guess. Info not provided is OK for other applications, you just want to avoid using that code in face to face situations.
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Opinions are Bartman's, not those of my employer. "A noble spirit embiggens the smallest man."

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