Would there be any gender discrimation issues if we indicated account holders as male, female on our core data account information? We currently have other CIP information listed there such as SSN, DOB, DL#. In the area for gender if nothing is chosed it defaults to 'not specified'. It seems silly to ask but....

As long as that information was not used in a credit decision, I see nothing wrong with it.

The CTR and SAR forms have a field for gender and we are supposed to enter the information if known so there should not be any issues with capturing the information.

As indicated, you're supposed to provide it if you know it; i.e. if the depositor is across the window you should be able to express an informed opinion. As for the other account holders who might be listed on the same CTR, you can leave it blank if you don't know.

Personally, there is no way I would start accumulating the information at account inception. First, because I don't have to. Second, because it facilitates a review for gender based discrimination; e.g. pay or return decisions on NSF checks, that would otherwise be very difficult.

Hang me if you must, but you're going to need to get your own rope.

Personally, I would rather have the actual information then get hung by the regulators using their surrogate name formulas for gender determination.

If the regulators are going to perform such a review on a bank, having or not having the information in your system is not going to stop them.

It's Pat!

And then there are those customers where you may have a difficult time determining their gender, and the customer might be disinclined to give you that information.

Hence, the "Unknown" option from the drop down list. Its use indicates you were willing to provide the information...