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#2146997 - 09/21/17 03:11 PM 2018 HMDA - new rules for gathering Ethnicity/Race
KerriAnnF Offline
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Joined: Nov 2016
Posts: 10
Under the amended and final HMDA rule, applicants now have additional choices available to them for "self-identification" purposes with regard to their (ethnicity/race). the revised rule has linked "new" sub-categories to existing "Main" categories, and, even offers an additional "other" category which applicant can choose from to self-identify further if they do not wish to select form the list. Appendix B states that (for a telephone application), the information on the collection form should be stated "orally". My question is this: Are creditors required to read ALL of the available sub-categories linked to each main category before asking the applicant to identify their Ethnicity or Race, or, is it acceptable to "only" read the "sub-categories" linked to a main category already selected by the applicant?. For Example: If an applicant is asked whether they are (Hispanic/Latino OR: NOT Hispanic/Latino) and they state that they are NOT Hispanic/Latino, is it OK "NOT" to read any of the (Hispanic) "sub-category" choices since they stated they are NOT Hispanic when they selected a main category? Its understood customer needs to know they have available choices but I'm needing to confirm if the HMDA rule is requiring a lender to read all "main" categories followed by a list of "all" of the available "sub" categories" up front before the customer responds or are we only required to read the sub-categories linked to a "main" category already selected by the applicant?

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#2147002 - 09/21/17 03:19 PM Re: 2018 HMDA - new rules for gathering Ethnicity/Race KerriAnnF
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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I would be concerned about not presenting all options.

They can select both Hispanic/Latino and Not Hispanic/Latino.

They can select sub-categories and not select a major aggregate category.

By shortening what is said, they won't have all options.
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#2147006 - 09/21/17 03:23 PM Re: 2018 HMDA - new rules for gathering Ethnicity/Race KerriAnnF
RR Joker Offline
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The Swamp
This is going to be so much fun. crazy
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#2147020 - 09/21/17 04:01 PM Re: 2018 HMDA - new rules for gathering Ethnicity/Race KerriAnnF
JWills, CRCM Offline
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JWills, CRCM
Joined: May 2013
Posts: 1,733
The Mitten State
I am so looking forward to it. NOT!!!
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#2147069 - 09/21/17 06:00 PM Re: 2018 HMDA - new rules for gathering Ethnicity/Race JWills, CRCM
Ski Offline
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Joined: May 2003
Posts: 639
South Louisiana
I am helping with setting up training for the 2018 rule.

I've been dealing with HMDA for about 36 of the 38 years I've been in banking.

I am retiring on 12/28/2017 so I'm not going to worry about it on 1/1/2018.

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#2147072 - 09/21/17 06:02 PM Re: 2018 HMDA - new rules for gathering Ethnicity/Race KerriAnnF
RR Joker Offline
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The Swamp
That's just mean, Ski. frown
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My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#2147081 - 09/21/17 06:18 PM Re: 2018 HMDA - new rules for gathering Ethnicity/Race Ski
Sinatra Fan Offline
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Sinatra Fan
Joined: Jul 2002
Posts: 5,568
New Jersey
I am very, very jealous, Ski. But congratulations on your impending retirement!
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Management is doing things right; leadership is doing the right things. Peter Drucker

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#2147085 - 09/21/17 06:30 PM Re: 2018 HMDA - new rules for gathering Ethnicity/Race KerriAnnF
RR Joker Offline
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RR Joker
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Posts: 20,644
The Swamp
What ^^^ said...absolute congrats!!!
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#2147088 - 09/21/17 06:41 PM Re: 2018 HMDA - new rules for gathering Ethnicity/Race KerriAnnF
Skittles Offline
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Skittles
Joined: Sep 2002
Posts: 13,963
TN
Me, too. Congratulations on your upcoming retirement!!!
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#2147094 - 09/21/17 06:45 PM Re: 2018 HMDA - new rules for gathering Ethnicity/Race KerriAnnF
hmdagal Offline
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hmdagal
Joined: Dec 2002
Posts: 3,814
Congratulations!

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