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#2144321 - 08/30/17 06:18 PM Collection Method if app not made F2F
Banker K, CRCM Offline
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Joined: Jan 2010
Posts: 293
Oklahoma
Hello, if an application is not taken in person (i.e. F2F...face-to-face), do we report the collection method as "not collected on the basis of visual observation or surname", or do we report as "NA"?

The CFPB's "NA" Guide doesn't list this as a scenario in which to report "NA" for the collection method field.

I asked the CFPB and they would not answer and said our bank had to make its own procedures based on its interpretation of Appendix B Instruction #10 ('thanks').
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#2144327 - 08/30/17 06:35 PM Re: Collection Method if app not made F2F Banker K, CRCM
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Validity Edit 630 says the following:

If Ethnicity of Applicant or Borrower Collected on the Basis of Visual Observation or Surname equals 3, then Ethnicity of Applicant or Borrower: 1 must equal 3 or 4

This is saying:

If you report NA for collected on basis of visual observation or surname (Code 3), then the ethnicity of the applicant/borrower must be either 3 ( Information not provided by applicant in mail, internet, or telephone application) or 4 (not applicable, such as an entity).

There is a corresponding edit for race:

If Race of Applicant or Borrower Collected on the Basis of Visual Observation or Surname equals 3 (not applicable), then Race of Applicant or Borrower: 1 must equal 6 (not provided in mail, internet or phone) or 7 (not applicable).


And for sex:

If Sex of Applicant or Borrower Collected on the Basis of Visual Observation or Surname equals 3, then Sex of Applicant or Borrower must equal 3 or 4..
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#2148777 - 10/05/17 01:07 PM Re: Collection Method if app not made F2F Banker K, CRCM
Banker K, CRCM Offline
Gold Star
Joined: Jan 2010
Posts: 293
Oklahoma
Thank you Kathleen.

I have a couple of follow-ups for you.

First, I forgot I posted this separately, and added it to a post someone else made about "Reporting Visual Observation" from 8/3/17. Someone on that thread told me I would have to report "NOT collected on basis..." for any phone/mail/internet apps (non-F2F apps) when the applicant is a person. They said I could not report "NA" in that field, because the CFPB's "Reporting Not Applicable" reference tool from 8/2017, reporting "NA" for the "collected on basis" field is only okay when the applicant is not a natural person (or purchased loan but we don't have those).
Do you think that document is expressly limiting all other circumstances of reporting "NA" in that field?
If so, I guess that when I have a non-F2F application, the collection method would have to be "NOT collected on basis...".
If that is how you understand it, then no need to read on the rest of my scenario. But please let me know.

However, if you don't think that document is limiting the "NA"...which is what the Validity Edit language seems to imply...it seems it would be possible to input "NA" on the collection method for an individual applicant in this scenario. Let me know what you think.
If the customer applies via phone, and does NOT complete the ethnicity and says they DO NOT WISH TO PROVIDE, then on my LAR, for the Ethnicity I will check "not provided in phone app", and I could check collection method of "NA" or I could check collection method of "NOT collected...". What do you think?
But on the flip side, if the customer applies via phone, and they DO complete the ethnicity, then on the LAR I would have to check collection method of "NOT collected...". Right?
So essentially, if the E/R/S is completed, then the collection method can only show "collected on basis..." or "NOT collected on basis...". If the E/R/S is completed, the collection method can never be "NA".

(I hope this made sense).
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All comments are mine & should not be taken as legal advice.

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