If we did not provide the customer with the new GMI options, just the old ones on the 1003, then we do report what is marked on the 1003? Or do we report as not provided? Or what is the best practice in these cases? The loan has already originated.

Were these applications taken in 2018?

Yes.

There's really not a good answer for you. The GMI form you used wasn't compliant. However, i certainly wouldn't choose the "not provided" option...they did provide....they provided on the form you gave them.

Hmmm...you're right, not a good answer haha. Thank you for your help!

Definitely report what you've got. And X out that part of the 1003 going forward.

Side bar: I'm curious how many are getting more than the same three answers we've always been getting. I'm not seeing much by way of additional answers beyond what was on last year's LAR. I'm beginning to get concerned that not having more may be a flag for examiners.

We get lots of write-ins...particularly for our Indian (Native American) borrowers.

That was my first thought when I was reading your post, Truffle. I've known too many lenders who, for some reason, seem afraid to ask GMI questions and just mark the information without ever asking for it.

I agree with raitchjay. You have a violation for not asking for all of the information, but I don't think you have any other option than to report what was provided.

We had a write-in RACE of German recently. Yeah, no way to really make that one work.

Yeah, we sort of fought a world war over that concept...LOL.

We get the occasional expanded answer, but mostly it's the same old 3.

We have yet to get an expanded answer. I have the same worry as Truffle.

I don't see how/why it would be a red flag. You can't make your applicants spend more time on the DI section than they want to, and a lot of people (my aforementioned customers notwithstanding, evidently) aren't interested in expounding on their race evidently.

If examiners look at the data and next year and some percentage of applicants in a certain situation provide expanded data, and 0% provided it at your institution (Or internally, if one particular lender is never getting expanded data), I could see that being a flag that your lender(s) might not be asking applicants and are just filling it in themselves.

On the other hand, if the industry as a whole is seeing that nobody is providing this information, then the regulators have a nice indication of how useful the expanded fields really are. Time will tell.

I'm hoping that the (non) usefulness of the expanded fields is what shows, Inherent.
While I'm hopeful that lenders are asking and not just filling out, I'm concerned that examiners are going to take off on the 'not asking enough' tangent.

Truffle - 9 months in and I haven't seen a single write-in yet. That being said, we also are not in a very diverse area. A very strong majority of persons in our area would all fit into one demographic, for which there are no write-in boxes.

I've seen on average 1 write in per 500 applications. Most of those are if the borrower sent in the application. If the lender took the application by phone than only 3 boxes are checked. I don't think most LO's bother explaining or asking for the extra fields.

Agreed, and hence my concern.

We get write-ins for American Indians and we get Asian Indian, Chinese and Mexican applicants. Not TONS but we are getting responses.

We've had a few expanded race or ethnicity, but we've had a lot more applications with the "I do not wish to provide" boxes checked, especially on the internet applications for our mortgage department. Some of the "I Do Not Wish to Provide" applicants will check the applicable box for gender, but not for race or ethnicity...

I tend to think the multiple do not wish boxes are confusing and buried.
The old way of just checking it once for the whole thing was easier to find and it was one and done.
I've had files where we're reporting do not wish/not provided/not provided.

Or completing the form right.

We have had some write-ins. We do have a bunch of sub-category designations under Asian. My favorite "bang my head against a wall moment" was when I had to confirm whether the write-in of "Filipino" under Other Pacific Islander was because the borrower didn't identify as an Asian-Filipino but instead purposefully identified as an Other Pacific Islander Filipino. It was a telephone application so I wasn't sure if it was a purposeful identification or an LO mistake. I'm sure you can guess which one was correct.