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#2152789 - 11/09/17 12:35 AM Another demographic info question
Bville Offline
Diamond Poster
Bville
Joined: May 2001
Posts: 1,282
Out West
In the unlikely event that we receive an application through the mail and:
1) none of the demographic information is filled out
2) the borrower did not mark "I do not wish to provide", and
3) the lender does not meet in person with the applicant prior to loan closing,

Would we simply report
"Information not provided in mail, internet, or phone application" for race, sex, and ethnicity, and
"Not collected on the basis of visual observation or surname"

What am I missing now?

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#2152791 - 11/09/17 02:54 AM Re: Another demographic info question Bville
Truffle Royale Offline

10K Club
Joined: Jul 2003
Posts: 17,395
You're not missing anything.
It sounds like you're doubting yourself when you really should be pleased because you've got this down pretty good.

oh, and fwiw, the scenario you used is not unlikely here. It happens all.the.time. smirk

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#2152826 - 11/09/17 02:52 PM Re: Another demographic info question Truffle Royale
Bville Offline
Diamond Poster
Bville
Joined: May 2001
Posts: 1,282
Out West
My hesitation comes from how the Sample Data collection form in Appendix B of HDMA is worded. The question about whether the information was collected on the basis of visual observation or surname is under the heading: "To Be completed by Financial Institution (for an application taken in person)"

There aren't any instructions I can find that say this field is only for in person applications.

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#2152838 - 11/09/17 03:29 PM Re: Another demographic info question Bville
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
I have that same issue, Bville. To me, that section should not be completed unless you meet in person at some point. When you think about it, that's the only time any of it would ever even apply.

It would seem to me you would only report

Information not provided in mail, internet, or phone application" for race, sex, and ethnicity
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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#2152859 - 11/09/17 04:53 PM Re: Another demographic info question Bville
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
The question about whether the information was collected on the basis of visual observation or surname is under the heading: "To Be completed by Financial Institution (for an application taken in person)"

There aren't any instructions I can find that say this field is only for in person applications.


That is the statement on the demographic collections form not the reporting form. If you did not take the application in person or never meet with the applicants during the application process then you do not complete that section of the collection form.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2152878 - 11/09/17 05:48 PM Re: Another demographic info question Bville
Truffle Royale Offline

10K Club
Joined: Jul 2003
Posts: 17,395
By extension then, would we leave that blank on the LAR for loans that are mail, fax, etc?
Just confirming. It's all this nitpickin' things that are going to drive me crazy.

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#2152889 - 11/09/17 06:16 PM Re: Another demographic info question Bville
hmdagal Offline
Power Poster
hmdagal
Joined: Dec 2002
Posts: 3,841
You would use code 2 - not collected on the basis...
There isn't an option to leave this field blank and code 3 (not applicable) is for purchased loans or loans where the applicant is not a natural person.

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#2154746 - 11/24/17 08:47 PM Re: Another demographic info question Bville
Banker K, CRCM Offline
Gold Star
Joined: Jan 2010
Posts: 293
Oklahoma
Agree with HMDA Gal.
_________________________
Compliance - A Painful Addiction

All comments are mine & should not be taken as legal advice.

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