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#2237391 - 05/29/20 10:16 PM Application Taken Method
C5nonmortgagebank Offline
Junior Member
Joined: Aug 2016
Posts: 30
Hello,

Had an internal debate recently whether an application with more than one borrower can have more than one Application Taken Method. The Demographic Information Addendum contains a place to identify how the application was taken (i.e. face to face, telephone, internet, etc.).

The question I am trying to answer is could/should one Demographic Information addendum indicate Face-to-Face if you took the application face-to-face with just one of the applicants but say the spouse was not present and only communicated via telephone should they have a different application taken method marked. Obviously this answer can have implications for what is reported for Ethnicity, Race and Sex.

Any thoughts on this?

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#2237414 - 06/01/20 02:38 PM Re: Application Taken Method C5nonmortgagebank
Truffle Royale Offline

10K Club
Joined: Jul 2003
Posts: 17,356
Absolutely the method taken should reflect the actual method taken. Doing anything else would be reporting false information.
There is nothing that says both demographic information forms must be taken the same way either.
Last edited by Truffle Royale; 06/01/20 03:18 PM.
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#2237446 - 06/01/20 08:06 PM Re: Application Taken Method C5nonmortgagebank
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I agree sort of. Truffle is correct but there's an assumption I want to clarify. You must collect Demographic Information at the time of application. If only one person is present, you collect (or attempt to) on that person. The applicant that is present can complete the info for the non-present applicant. If they don't, you shouldn't try to collect on that person later. You would indicate the other applicant was not present.

For example, if I came in to your office and you collected my demographic information, I could fill out the co-applicant's info too. If I didn't complete the info on the co-applicant, you shouldn't leave it "open" and complete it later. Here's the instructions from Appendix B.

A co-applicant may provide an absent co-applicant’s ethnicity, race, and sex on behalf of the absent co-applicant. If the information is not provided for an absent co-applicant, you must report ‘‘information not provided by applicant in mail, internet, or telephone application’’ for the absent co- applicant. [Appendix B to §1003 #5]

Now, it could be that I'm in person and the co-applicant is on the phone, but that seems unusual.
_________________________
David Dickinson
http://www.bankerscompliance.com

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