applicant filled out ethnicity and sex but for race they put NA.

Do we report this even though inconsistent with answers for sex and ethnicity?

Yes, report exactly what the applicant provides.

NA? They wrote "NA" in an other category or said they didn't wish to provide? If they wrote "NA," then report what they wrote. If they said they didn't wish to provide, and the app was in person, then you would fill out based on visual observation. If it was telephone or internet, then report do not wish to provide.

I would report as "Information not provided." The code for "NA" is used if the requirement to report the race of the applicant does not apply to this particular loan. But it's a natural perspn applying, so the requirement to report the applicant's race does apply. And since the applicant chose not to disclose his/her race, "information not provided" would be the appropriate code to use. If reported as "NA" I can see an examiner asking what's the reason that the requirement to report the race does not apply to this loan. I don't think "Because the applicant said so" would be a satisfactory response.

I'll second Inherent Risk's comments. If they wrote "NA", then you need to report exactly what they wrote.

Appendix B to §1003 #8 states "You must report the ethnicity, race, and sex of an applicant as provided by the applicant."

I've seen some odd ones, too. One person wrote 'Tennessean' and that's what we put on the LAR.

I'm with TomS on this.......the only place to put "NA" is in the free form section.....and i think you'd have to make an actual race choice first to then be able to type in "NA". I wouldn't be comfortable either saying "we reported that the race was NA because the applicant said those requirements didn't apply".

If you could type "NA" in the free form section without having to check another actual race, then i would agree with typing in "NA" there if the applicant wrote that term out.

If i'm mistaken about the free form area (that you CAN write in "NA" without first making a choice like "white"), then i'll retract. But actually checking "NA" follows rules within Reg. C about when the gathering of race does and does not apply. An applicant's whim can't (IMHO) usurp the strict requirements of Reg. C for when the NA box should or should not be checked.

IOW, the way i see it......you would be correct to type in "NA" under race.....if you could without checking ANY other actual race choice first, because the applicant didn't make a choice. But if you cannot type in "NA" without first making a race choice that the applicant did NOT make on the application, then

Checking the "Not applicable" box is not correct in my opinion, because it is not indicating a choice made by the applicant on the application, but rather indicating that the DI requirements of Reg. C do NOT apply for this application, and that isn't true.

I think we are making a lot of assumptions about what actually happened here and disagreeing due to those assumptions. The OP said "put NA," which could mean a lot of things, and depending on what it means would be reported differently.

That said, you don't actually HAVE to select a race to use a freeform field. The FIG states this on what to report if a borrower fills in a free form without checking a race:

"If the Applicant or Borrower did not select any race(s) and only provided race(s) in the Race of Applicant or Borrower: Free Form Text Field for American Indian or Alaska Native Enrolled or Principal Tribe, Race of Applicant or Borrower: Free Form Text Field for Other Asian, and/or Race of Applicant or Borrower: Free Form Text Field for Other Pacific Islander, beither leave this data fieldblank or enter, as appropriate, Code 1, 27, or 44."

You would have to put it under a specific race selection's free form field though, so if they just scribbled "NA" nowhere in particular, then I don't really know how I'd report it. There is no general race free form field, so I'm just going to hope that never comes up .