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#2202548 - 01/10/19 02:45 PM Demographic Information
Lizz Offline
100 Club
Joined: Aug 2013
Posts: 128
Dunkirk NY
Fields 31-32 and 49-50 -where you give the description of how Ethnicity race and sex was taken - (1) Collected on the basis of visual observation or surname - (2) Not collected on the basis of visual observation and surname. (3) not applicable

Question - When would you use (3) Not applicable ??
For applications taken Face to Face - would you use (1) Collected on the basis of visual observation?
For those application that are taken by Telephone /Internet/ mail - would you use (2) Not collected on the basis of visual observation?

Just trying to be clear with the selected fields.

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#2202606 - 01/10/19 06:08 PM Re: Demographic Information Lizz
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
NA (code 3) is for purchase loans and when the applicant is a non-natural person (an entity).

There's much debate about this, but knowing what I just stated above (from the FIG), you have to code everything else as a 1 or 2 (that's the camp I'm in). Face to face applications could be a 1 or 2, depending on if the applicant completed the info or the loan officer did. Non-face to face applications would always be code 2 (No - the LO didn't complete the info based on visual observation).

Some say their software automatically puts code 3 for all non-face to face apps.
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David Dickinson
http://www.bankerscompliance.com

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#2202698 - 01/11/19 01:28 PM Re: Demographic Information Lizz
Lizz Offline
100 Club
Joined: Aug 2013
Posts: 128
Dunkirk NY
Thanks Dave!

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#2203548 - 01/22/19 03:26 PM Re: Demographic Information Lizz
HuntFish Offline
Member
Joined: Jan 2010
Posts: 66
undecided
Non-face to face applications would always be code 2 (No - the LO didn't complete the info based on visual observation).

David, couldn't a non-face to face application have the occasional code 1? IF the application is incomplete, lender meets with applicant prior to closing; and applicant has not orally(phone) stated or marked (internet/mail) "I do not wish....".

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#2203555 - 01/22/19 04:22 PM Re: Demographic Information Lizz
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
HuntFish: Yes, that's true, but it wouldn't be a "non-face to face application". The application would be completed in person.
_________________________
David Dickinson
http://www.bankerscompliance.com

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#2203573 - 01/22/19 05:20 PM Re: Demographic Information Lizz
HuntFish Offline
Member
Joined: Jan 2010
Posts: 66
undecided
Hmmmm, that changes my chart just a bit. Thank you!

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