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#2130657 - 05/16/17 06:15 PM
HMDA
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New Poster
Joined: Nov 2016
Posts: 10
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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
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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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
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Diamond Poster
Joined: Dec 2013
Posts: 1,399
CA
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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
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Joined: Aug 2001
Posts: 7,351
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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
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Joined: Oct 2009
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OK
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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
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Gold Star
Joined: Jun 2010
Posts: 257
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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
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10K Club
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Posts: 18,762
Central City, NE
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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
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New Poster
Joined: Nov 2016
Posts: 10
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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
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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It is not addressed.
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#2130898 - 05/18/17 01:43 PM
Re: HMDA
KerriAnnF
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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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#2131447 - 05/23/17 01:20 PM
Re: HMDA
David Dickinson
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10K Club
Joined: Jul 2001
Posts: 83,227
Galveston, TX
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What are their children (not here . . . yet)? David - what a silly question - they are your grandchildren of course 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
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Joined: Oct 2009
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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)?
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
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10K Club
Joined: Nov 2002
Posts: 20,654
The Swamp
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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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#2131476 - 05/23/17 02:49 PM
Re: HMDA
KerriAnnF
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Power Poster
Joined: Oct 2009
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OK
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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
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Power Poster
Joined: Oct 2009
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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
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10K Club
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
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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
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Posts: 17,395
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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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#2131483 - 05/23/17 03:03 PM
Re: HMDA
KerriAnnF
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Power Poster
Joined: Oct 2009
Posts: 9,088
OK
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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
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Power Poster
Joined: Oct 2009
Posts: 9,088
OK
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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
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10K Club
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
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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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