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#2267043 - 03/01/22 05:27 PM GMI on an unsecured credit application
JoeG Offline
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Joined: Nov 2013
Posts: 124
DuPage county, IL
Our unsecured credit applications for home improvement loans does not contain GMI questions and I don't think it is a requirement. In addition, 99% of these applications are received via the internet or fax so we do not see who is applying unless an applicant includes a copy of their ID with their application.

I don't believe there is a requirement to ask for GMI on our unsecured application. However, are we allowed to place GMI questions on this type of credit application if we so desire? Asking for GMI would enable our compliance dept. to monitor for discrimination based on ethnicity, race, sex, marital status, etc.

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#2267045 - 03/01/22 05:38 PM Re: GMI on an unsecured credit application JoeG
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 79,912
Galveston, TX
GMI on unsecured credit is required by neither Regulation B or HMDA. Under what provisions would you be collecting this data?
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#2267064 - 03/01/22 09:00 PM Re: GMI on an unsecured credit application JoeG
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 46,957
Bloomington, IN
Asking for GMI would enable our compliance dept. to monitor for discrimination based on ethnicity, race, sex, marital status, etc.

See 1002.5(b). However if you are going to collect this information under the guise of a self-test monitoring program I highly recommend you get your legal council involved.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2267067 - 03/01/22 09:41 PM Re: GMI on an unsecured credit application JoeG
Rocky P Offline
Power Poster
Joined: Jun 2003
Posts: 7,441
Florida
The FRB had excel tables which could be used for proxies for ethnicity and gender. That might be safer than collecting potentially prohibited information

CFPB had a publication about using publicly available information.
https://files.consumerfinance.gov/f/201409_cfpb_report_proxy-methodology.pdf
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