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#2281228 - 02/16/23 09:00 PM GMI Clarification Needed
Newbie06 Offline
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Joined: Mar 2006
Posts: 717
We typically do not run into the situation where the customer doesn't want to provide demographic information. In one case we had the customer indicate, "I do not wish to provide this information" for the Race category. It's my understanding if the application was taken face to face then the lender is to make a choice based on visual observation. Are we then required, for HMDA purposes, to indicate what the customer marked or what the lender decided based on visual observation on the HMDA LAR?

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#2281229 - 02/16/23 09:13 PM Re: GMI Clarification Needed Newbie06
hmdagal Offline
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hmdagal
Joined: Dec 2002
Posts: 3,841
You report what the lender observed. Also, the 3 'visually observed' fields should have code '1'.

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#2281232 - 02/16/23 09:28 PM Re: GMI Clarification Needed Newbie06
Newbie06 Offline
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Joined: Mar 2006
Posts: 717
hmdagal, I will indicate a 1 for the Race as that was the only area the customer did not want to provide and lender made a visual observation. Thanks for the clarification.

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