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#2261391 - 10/21/21 06:24 PM New 1003 and non HMDA reporter
Love those Regs Offline
Gold Star
Joined: Apr 2002
Posts: 290
Southern State
We are not a HMDA reporter so when appropriate, we collect demographic info based on Reg. B requirements. Is there a version of the new 1003 that only has the Reg. B aggregate collection section? All I can find has the disaggregate version that HMDA reporters would use.
Opinions are mine and subject to change frequently

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Lending Compliance
#2261411 - 10/21/21 08:51 PM Re: New 1003 and non HMDA reporter Love those Regs
rlcarey Offline
10K Club
Joined: Jul 2001
Posts: 78,965
Galveston, TX
I do not see it as an issue as the information is interchangeable, whether or not you are a HMDA reporter.
Official Interpretation
13(a) Information to be requested.

7. Data collection under Regulation C. For applications subject to § 1002.13(a)(1), a creditor that collects information about the ethnicity, race, and sex of an applicant in compliance with the requirements of appendix B to 12 CFR part 1003 is acting in compliance with § 1002.13 concerning the collection of an applicant's ethnicity, race, and sex information. See also comment 5(a)(2)-2.

8. Application-by-application basis. For applications subject to § 1002.13(a)(1), a creditor may choose on an application-by-application basis whether to collect aggregate information pursuant to § 1002.13(a)(1)(i)(A) or disaggregated information pursuant to § 1002.13(a)(1)(i)(B) about the ethnicity and race of the applicant.
The opinions expressed here should not be construed to be those of my employer:

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#2261452 - 10/22/21 03:49 PM Re: New 1003 and non HMDA reporter Love those Regs
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,614
I agree with Randy that it won't be an issue under Regulation B. Plus, there is no regulatory requirement to use the URLA/1003, but check with your investors (if you sell your loans) to see if they have a requirement.
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.

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