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#2130657 - 05/16/17 06:15 PM HMDA
KerriAnnF Offline
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When taking an application (in-person) and the applicant does NOT wish to disclose Race, Ethnicity or Sex, Lenders must report based on VISUAL Observation...

QUESTION:
When we are collecting and reporting GMI based on VISUAL observation, can the originator select MULTIPLE Races? The guidance is clear on reporting (Sex) – if reported on a visual basis, we select only ONE gender. But, does this same rule apply to reporting the RACE as well ?

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#2130709 - 05/16/17 10:16 PM Re: HMDA KerriAnnF
rlcarey Offline
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How would you visually determine that someone is of multiple races?
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#2130712 - 05/16/17 10:50 PM Re: HMDA KerriAnnF
Darth HMDA, CRCM, CAMS Offline
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im pale and freckly (white) but short with Asian eyes and my middle/last name are distinctly Japanese

I wouldn't be offended if someone marked both

most people think im Hispanic hahaha
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#2130737 - 05/17/17 01:30 PM Re: HMDA KerriAnnF
swiggles Offline
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I had friend, back in the day, named Pedro Chang. He looked more Asian than Hispanic, but spoke Spanish fluently and considered himself Hispanic.
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#2130751 - 05/17/17 01:55 PM Re: HMDA KerriAnnF
raitchjay Offline
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If you're a Filipino, you're pretty much by definition Hispanic (at least culturally, to a degree) and Asian.
Last edited by raitchjay; 05/17/17 02:04 PM.
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#2130754 - 05/17/17 02:08 PM Re: HMDA KerriAnnF
GTS333 Offline
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You need to read Appendix B to the revised Regulation C, there are strict limits on what a bank can report for the new expanded race/ethnicity HMDA collection. In short, a bank cannot guess at a disaggregate race or ethnicity subcategory based on visual observation or surname, so you're essentially limited to guessing using the existing aggregate categories which is the same options you have today in that regard.
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#2130769 - 05/17/17 03:11 PM Re: HMDA KerriAnnF
David Dickinson Offline
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When we are collecting and reporting GMI based on VISUAL observation, can the originator select MULTIPLE Races? The guidance is clear on reporting (Sex) – if reported on a visual basis, we select only ONE gender. But, does this same rule apply to reporting the RACE as well ?
GT is right. When the lender selects ethnicity and race, they are limited to main categories only. IOW, the lender can't choose sub ethnicity or sub race categories, but they can choose multiple main race/ethnicity.

#10 in Appendix B states this:
If the applicant chooses not to provide the information… note this fact on the collection form and then collect the applicant’s ethnicity, race, and sex on the basis of visual observation or surname. You must report whether the applicant’s ethnicity, race, and sex was collected on the basis of visual observation or surname. When you collect an applicant’s ethnicity, race, and sex on the basis of visual observation or surname, you must select from the following aggregate categories:
It then lists the main ethnicity and race categories.
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#2130809 - 05/17/17 05:43 PM Re: HMDA KerriAnnF
KerriAnnF Offline
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I understand GT's reply to state that per Appendix B, a bank cannot guess at the new (disaggregate) categories for race/ethnicity based on visual observation and surname and we are limited to the standard (aggregate) categories, however,


The question is: can we select "multiple" races from the ("aggregate") categories for RACE or are we limited to only one ?

We understood that only applicants can self-identify using ("disaggregate") categories and banks should not guess at these but when collecting based on visual observation and we are using the standard (aggregate) categories, does the rule require that we select only one from the "aggregate" list or is it OK (based on visual observation) to select ---more--- than one from the "aggregate" category?

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#2130811 - 05/17/17 05:57 PM Re: HMDA KerriAnnF
rlcarey Offline
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It is not addressed.
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#2130836 - 05/17/17 08:16 PM Re: HMDA KerriAnnF
dlucas Offline
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My question: why would you want to? Don't go there! smile

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#2130896 - 05/18/17 01:38 PM Re: HMDA KerriAnnF
David Dickinson Offline
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We are only told we cannot pick sub categories. If you're guessing, based on visual observation, you certainly could guess more than one main category. Maybe you actually know the applicant's ethnicity/race. For instance, if you knew one of their parent's hispanic and the other was non-hispanic, there's nothing wrong with marking both ethnicities. Or if you knew one parent was white and the other was black, why not mark both?
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#2130898 - 05/18/17 01:43 PM Re: HMDA KerriAnnF
raitchjay Offline
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I have never thought it was an option to mark both ethnicities....multiple races? Yes.....but not multiple (both) ethnicities. Not saying that's wrong...just a new one on me if it's right.
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#2131421 - 05/23/17 12:45 AM Re: HMDA KerriAnnF
David Dickinson Offline
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My son is non-hispanic (look at my picture). He has married a young lady that is 100% hispanic. What are their children (not here . . . yet)?
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#2131447 - 05/23/17 01:20 PM Re: HMDA David Dickinson
rlcarey Offline
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Originally Posted By David Dickinson
What are their children (not here . . . yet)?


David - what a silly question - they are your grandchildren of course smile I wish you many - the six that we have are the joy of our lives.
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#2131451 - 05/23/17 01:34 PM Re: HMDA David Dickinson
raitchjay Offline
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OK
Originally Posted By David Dickinson
My son is non-hispanic (look at my picture). He has married a young lady that is 100% hispanic. What are their children (not here . . . yet)?


I don't know.....but i don't think for HMDA purposes they can be both "Hispanic" and the negative of that, "not Hispanic". The GIR gives the command that applicants must be given the option to choose multiple races--the same option isn't given for ethnicity.
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#2131467 - 05/23/17 01:58 PM Re: HMDA KerriAnnF
RR Joker Offline
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I would agree...it's an either or...not both...it's however a person chooses to 'identify'.
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#2131475 - 05/23/17 02:41 PM Re: HMDA KerriAnnF
Truffle Royale Offline

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Well, my granddaughter IS here and she's half Peruvian and half European white mix. So she DEFINITELY marks both Hispanic and not Hispanic on all her applications, etc. because that's how she chooses to identify. While the GIR may only speak to multiple race categories having to be allowed, it doesn't speak to multiple ethnicities NOT being allowed.

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#2131476 - 05/23/17 02:49 PM Re: HMDA KerriAnnF
raitchjay Offline
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So if someone selects "hispanic, not hispanic, white, male, female"...you'd report it that way?
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#2131477 - 05/23/17 02:51 PM Re: HMDA KerriAnnF
raitchjay Offline
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And most people of Latin American descent are a mix of European (Spanish) and other (Native American, black, etc.)--it's still up to them how they self-identify when it comes to being Hispanic or not Hispanic. Being part European (white) doesn't mean you're part "not Hispanic"--Spaniards are WHITE.
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#2131479 - 05/23/17 02:55 PM Re: HMDA KerriAnnF
Dan Persfull Online
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You can't report it that way. When you enter the applicant's or co-applicant's ethnicity you have to choose one or the other. You can't choose both.
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#2131481 - 05/23/17 03:03 PM Re: HMDA KerriAnnF
Truffle Royale Offline

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That's not what David said above, Dan, and I agree with him. Where does it say an applicant can't mark both ethnicities?

raitchjay, the answer to "So if someone selects "hispanic, not hispanic, white, male, female"...you'd report it that way?" is yes, you report it that way. It's not the bank's place to question what the borrower marks. It's our job to report what they mark no matter what. From the FFIEC website: "A lender must report whatever information the applicant supplies, whether partial or complete."

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#2131482 - 05/23/17 03:03 PM Re: HMDA KerriAnnF
Truffle Royale Offline

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Wait, Dan are you saying the system won't let you enter both?

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#2131483 - 05/23/17 03:03 PM Re: HMDA KerriAnnF
raitchjay Offline
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It's the bank's place to follow the rules of Reg. C and the GIR (currently)......and IMO, they don't tell you to allow multiple choices anywhere but race.
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#2131484 - 05/23/17 03:06 PM Re: HMDA KerriAnnF
raitchjay Offline
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The race choices by definition aren't inclusive...you CAN be multiple races. Ethnicity is a self-identification matter...and the very important distinction of "not"...you can't be "Hispanic" and "not Hispanic"....that would be like saying "i'm Italian and not Italian...or I'm Irish and not Irish".
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#2131486 - 05/23/17 03:10 PM Re: HMDA KerriAnnF
Dan Persfull Online
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Wait, Dan are you saying the system won't let you enter both?

I have not seen any system that will allow you to report both Hispanic and Not Hispanic for the applicant of co-applicant. You have to choose one or the other under Ethnicity.

Under the new rules I'm sure the systems will allow you to choose Hispanic and the aggregate categories but I do not anticipate them allowing you to choose both Hispanic and Not Hispanic for the applicant or co-applicant.
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