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#146506 - 01/07/04 08:16 PM Dumb HMDA question
Anonymous
Unregistered

OK, back to ethnicity. If we have an applicant who is white or black or asian or green or purple, we would use code 2 (Not Hispanic or Latino), and I understand that 3 (not provided) would be used for internet, mail or phone apps... Can someone clarify when I would use code 4 (N/A)?
PLEASE.....?

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Lending Compliance
#146507 - 01/07/04 08:19 PM Re: Dumb HMDA question
Anonymous
Unregistered

I think you would use code 4 if the applicant is a non-person (A corporation for example)

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#146508 - 01/07/04 08:19 PM Re: Dumb HMDA question
Dan Persfull Offline
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Dan Persfull
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Posts: 47,674
Bloomington, IN
Loans to Corp., LLCs, Partnerships, etc. (not a natural person).
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The opinions expressed are mine and they are not to be taken as legal advice.

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#146509 - 01/07/04 08:20 PM Re: Dumb HMDA question
Anonymous
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Code 4 is used if the applicant/co-applicant is not a natural person (i.e. corporation or partnership) or if the information is not available because the loan was purchased from another institution

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#146510 - 01/07/04 08:21 PM Re: Dumb HMDA question
Anonymous
Unregistered

Thanks...

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#146511 - 01/07/04 08:25 PM Re: Dumb HMDA question
Patsy Cline Offline
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On the road...
Quote:

OK, back to ethnicity. If we have an applicant who is white or black or asian or green or purple, we would use code 2 (Not Hispanic or Latino)




I'm confused by your first statement... maybe I misunderstood. They can be any race and also be hispanic or latino. If they select "white or black or asian or green or purple" that does not disqualify them from being hispanic or latino.
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#146512 - 01/07/04 08:32 PM Re: Dumb HMDA question
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
Good catch, and you are absolutely correct.
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#146513 - 01/07/04 08:37 PM Re: Dumb HMDA question
1995Banker Offline
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Posts: 241
Well, that's kinda what I thought.

Now.....if their ethnicity is Hispanic or Latino, and their race is not American Indian or Alaska Native; Native Hawaiian or Other Pacific Islander; Asian; Black or African American...am I correct in assuming we would check "White"?
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#146514 - 01/07/04 08:37 PM Re: Dumb HMDA question
Patsy Cline Offline
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On the road...
Quote:

Good catch, and you are absolutely correct.




Thanks Dan!
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Michelle CRCM

"What would you attempt to do if you knew you could not fail?" ~ unknown


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#146515 - 01/07/04 08:48 PM Re: Dumb HMDA question
Dan Persfull Offline
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Dan Persfull
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Posts: 47,674
Bloomington, IN
Quote:

Now.....if their ethnicity is Hispanic or Latino, and their race is not American Indian or Alaska Native; Native Hawaiian or Other Pacific Islander; Asian; Black or African American...am I correct in assuming we would check "White"?




If they do not furnish the information, and it is a face to face application, you make your best guess.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#146516 - 01/08/04 04:10 PM Re: Dumb HMDA question
SMQ, CRCM Offline
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Between the lines
Also, they could be hispanic or latino under ethnicity AND they could be American Indian & African American & White --- multi-racial. The new HMDA allows for 4 choices now under Race.
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#146517 - 01/08/04 09:01 PM Re: Dumb HMDA question
Suwannee Offline
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Suwannee
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Florida
HMDA now allows applicants to make up to five selections for race, not four. The applicants can select all of the race categories that apply, and there are five different races listed.
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#146518 - 01/09/04 12:03 AM Re: Dumb HMDA question
SMQ, CRCM Offline
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Between the lines
Ooops, thanks. I was looking at a sample LAR that only had 4 spaces. Thanks for clearing that up for all us BOL users. I am still trying to figure out how to make our database accept more than one selection --- but that's another HMDA headache.
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#146519 - 01/09/04 09:34 PM Re: Dumb HMDA question
Anonymous
Unregistered

Quote:

Code 4 is used if the applicant/co-applicant is not a natural person (i.e. corporation or partnership) or if the information is not available because the loan was purchased from another institution




What if the applicant is a sole proprietorship (i.e. John Doe dba John's Garage)? Would you automatically choose #4 or would you see if John was going to occupy the property?

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#146520 - 01/09/04 09:45 PM Re: Dumb HMDA question
hmdagal Offline
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hmdagal
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Occupancy is not a factor in collecting monitoring information. Look at how the note is signed. If it's John Doe, dba John's Garage, collect the information. If it's John's Garage, signed by John Doe, Sole Proprietor, use the codes for NA.

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#146521 - 01/13/04 04:45 PM Re: Dumb HMDA question
Anonymous
Unregistered

Quote:

Occupancy is not a factor in collecting monitoring information. Look at how the note is signed. If it's John Doe, dba John's Garage, collect the information. If it's John's Garage, signed by John Doe, Sole Proprietor, use the codes for NA.




I am the anonymous who originally posed the question and my bank's Compliance Officer contacted hmdahelp@frb.org and this is what they said:

A sole proprietorship is not a natural person for monitoring information. Report the customer as John's Garage.

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