Is it ok to collect Demographic Information on prequalifications?

2. Prequalification. A prequalification request is a request by a prospective loan applicant (other than a request for preapproval) for a preliminary determination on whether the prospective loan applicant would likely qualify for credit under an institution's standards, or for a determination on the amount of credit for which the prospective applicant would likely qualify. Some institutions evaluate prequalification requests through a procedure that is separate from the institution's normal loan application process; others use the same process. In either case, Regulation C does not require an institution to report prequalification requests on the loan/application register, even though these requests may constitute applications under Regulation B for purposes of adverse action notices.

So, you could not gather under Reg. C. However, since it is most likely an application under Reg. B, you would have to comply with 1002.13 if it was for a primary residence.

Under 1002.2(f) Official Interpreation -3 a prequalification does not beome an application until the crediotr decides to decline the request and communicates this to the consumer. Therefore, at the time the consumer request the prequalification should you request the monitoring information because you technically do not have an application unless you decline?