I just want to point out again...Spain is in Europe. Many if not most Spaniards are "white". I don't see how being "half European white mix" is some sort of disqualifier for being "Hispanic".

Or, I'm half Peruvian.

Let's be honest here. The government wants to know that banks aren't redlining against anyone. The reality is that having a preponderance of white male borrowers is going to raise more red flags than having both ethnicities marked.

I won't stop an applicant from marking both. If the system stops me from reporting both, I'll have to make a choice and I'll document for backup in case it gets pulled in an exam.

oh, and Peru isn't in Europe, but it is Hispanic.

Your quote was "half European white mix".....which you seemed to be saying would support the "not Hispanic" designation.....i'm just saying that's not any kind of disqualifier because contrary to what everyone wants to say and think about "being Hispanic", it has nothing to do with the color of one's skin.

I totally agree. Skin color has nothing to do with ethnicity. Saying Black Irish doesn't mean someone is black either. I just didn't want to faux pas by saying 'white Anglo Saxon and Protestant'.

I used to teach geography, and it's just a sore spot with me.....i have talked til i'm blue in the face with lenders who think that "Hispanic" is a race...and they give me funny looks when i tell them that someone who marks "Hispanic" still must have a race picked...and that they can pick "white" too. They act like it's impossible to be "white" and "Hispanic". Um......you need to look at the history of colonization in Latin America....WHITE Spaniards intermarried with Native Americans and African Americans. A black Cuban and a white Spaniard don't look much alike...but they're both "Hispanic". A typical "Mexican" is a mix of Native American and white European.

I'm still on the side of you can't be a + and a -. You are or you are not. You can't be both. I can go with male and female before I could go with Hispanic, but not Hispanic. You are...or you are not. Pick one.

All of this aside, and pardon me for shouting but, WHERE DOES IT SAY THEY CAN'T MARK BOTH ETHNICITIES?
If the issue is that the system will not let you mark both ethnicities, then I understand where Dan is coming from purely with regard to actual reporting on the LAR.
Nowhere in the Reg or GIR have I seen where they borrow is allowed to go crazy marking all the races they want but they are prohibited from marking both ethnicities or sexes for that matter.

Yoohoo, David, could use a little help here.

Where does it say they can't write a 4 page paragraph about the history of their ethnicity and/or race and that the lender should then include such a narrative in the LAR submission? And what do you mean you haven't seen it? It explicitly says they must be allowed to choose multiple races...it says no such thing for ethnicity.

Such questions are why i'm a strict constructionist when it comes to regulations--i do what the regulations tell me to do...nothing more...nothing less.

I'm not sure if HMDA has a specific answer, but the guidance does point to census guidance. The 2010 census guidance includes:

"The 2010 Census question on Hispanic origin included five separate response categories and one area where respondents could write-in a specific Hispanic origin group. The first response category is intended for respondents who do not identify as Hispanic. The remaining response categories (“Mexican, Mexican Am., or Chicano”; “Puerto Rican”; “Cuban”; and “Another Hispanic, Latino, or Spanish origin”) and write-in answers can be combined to create the OMB category of Hispanic."

https://www.census.gov/prod/cen2010/briefs/c2010br-04.pdf

So my guess would be that you can't check Hispanic and Not Hispanic. Hispanic + Not Hispanic = 100% in the census data.

It might all change in 3 years though.
http://www.pewresearch.org/fact-tank/201...-and-ethnicity/

I don't think anyone is saying you must report two ethnicity choices or a narrative paragraph if the applicant writes one. I think they're saying not to point your bony finger at the applicant and say he/she can't check more than one box. The applicant, when completing an application can do/check/write anything they want to. Then you have to make a choice about what to report according to the requirements of Reg C.

You are supposed to read the instructions to applicants prior to gathering the GMI. (Before i go any further, let me say i think this is a bit of a red herring...i think the average person understands that when given the choice of "Hispanic" or "not Hispanic", you have to choose one or the other....not both.) If there becomes a problem of getting applications with both choices under ethnicity selected (i don't anticipate ever having this problem), i would have no problem adding to our instructions to the applicants "please, only make one selection". I'd leave my bony finger out of it.

Here's what I see in the Instructions:

Appendix B to Part 1003--Form and Instructions for Data Collection on Ethnicity, Race, and Sex
8. You must report the ethnicity, race, and sex of an applicant as provided by the applicant.
9. You must offer the applicant the option of selecting more than one ethnicity or race. If an applicant selects more than one ethnicity or race, you must report each selected designation, subject to the limits described below.
i. Ethnicity—Aggregate categories and subcategories. There are two aggregate ethnicity categories: Hispanic or Latino; and Not Hispanic or Latino. If an applicant selects Hispanic or Latino, the applicant may also select up to four ethnicity subcategories: Mexican; Puerto Rican; Cuban; and Other Hispanic or Latino. You must report each aggregate ethnicity category and each ethnicity subcategory selected by the applicant.

My emphases are shown in red above.

SF.....under new HMDA, there are multiple sub-categories of ethnicity, so yes, i agree, they will be able to make multiple selection under the subcategories.

And you do not see the same language in the current version of Appendix B.

That's correct; I quoted from the instructions that are effective January 1, 2018.

We've had applicants, that even being read or instructed to read the GMI section...are smarty pants and check every single box. I've got no problem with that...but I do know for sure that the current software I use only has one category available per reportable applicant...so there would be zero way to report what they checked...but I could check up to 5 races for them They can also only be male or female as there is only one box/applicant.

But we don't know what the new software is going to allow because it's not out yet, right?
I haven't used the formatting tool because my LAR is bigger than they say it's meant for.

I have the new aggregate/disaggregate stuff and it will allow for multiple choices for ethnicity and sex. How it would fill over to the LAR, I've no idea yet.

Questsoft won't allow multiple ethnicity choices in their 2018 test module....i'm not saying that means they're right....but if you try to show someone as both "Hispanic" and "not Hispanic"...it won't let you.

The 2018 rules are very clear to me. The instructions say (as Sinatra posted above), we are to report "as provided by the applicant." And we "must offer the applicant the option of selecting more than one ethnicity" . . .. "If an applicant selects more than one ethnicity or race, you must report each selected designation". It also very clearly states "You must report each aggregate ethnicity category". That's not sub-ethnicities - that's main categories (Hispanic and Non-Hispanic). What could say this more clearly or where is the confusion?

The confusion is that if the govt. wanted more than one choice available for ethnicity, they shouldn't label it "this thing" and "the opposite of this thing". You can't be "deaf" and "not deaf". They should have labelled it "Hispanic", "not Hispanic", "a little bit Hispanic", "mostly Hispanic", etc. if that's what they wanted. Especially when you have not changed the main ethnicity labels and have previously not allowed such reporting.

If an applicant selects more than one ethnicity or race, you must report each selected designation".

How do you propose we report the Ethnicity as both "Hispanic" & "Not Hispanic"? I'm not asking about reporting the subcategories if Hispanic is chosen and they also choose to complete the subcategories. The software will be geared to allow for that reporting but I do not anticipate the software will be geared to allow Hispanic & Not Hispanic to be reported for the same applicant, nor do I see why it would be.

Saying I'm Hispanic but I'm not Hispanic is like saying I'm a little bit pregnant but I'm not really pregnant. You either are or you're not.

Just curious - Is "Not Hispanic" really an ethnicity?

Dan....i have had the same thought, and IMO, no, "not Hispanic" is not an ethnicity. That's why i think that the govt.'s labels are goofy.......they should label that section the "Hispanic or not Hispanic" section, not "Ethnicity". I'm "not Hispanic", and that tells you nothing about my ethnicity...i could be Welsh, Irish, Italian, Greek, Russian, Portugese, French.....

There are all different types of "ethnicity" that have nothing to do with being Hispanic or not.

They have labeled it so that, seemingly, answering the question of whether one is Hispanic or not is the end-all, be-all, all there is to know about one's "ethnicity". If "not Hispanic" is an ethnicity, then so is "not Greek", "not Italian", "not Irish", "not Welsh", "not Russian".

What if race contained only two categories, "white" and "non-white", similar to the binary option for ethnicity? Then anyone of a mixed racial heritage could legitimately check both options. "On my father's side, I'm non-white; on my mother's side, I'm white." Yes, that would seem to be a logical impossibility, but the response is conditioned by the options created for the respondent, and the terms given to the options.

In my opinion, everyone would have been better served if the categories for ethnicity were: Hispanic, not Hispanic, mixed. Then every applicant would be able to select one option. For race, the current categories would serve, since there are so many possible combinations; applicants could check multiple categories if needed (think Tiger Woods [although he'll never need to apply for a mortgage loan]).