It appears that the CFPB anticipates that information may be provided by someone other than each principle owners. From the final rule:
"The Bureau believes it is reasonable to assume that if the person filling out the data collection form on behalf of an applicant does not feel comfortable providing the information for any reason, including because they are not the principal owner at issue or do not believe they can provide accurate responses, that they will exercise the right to refuse to provide the requested information. Further, an applicant can also choose to not fill out the entirety of the form, to not provide responses to a specific question, or to select the “I do not wish to provide this information” or similar response option available for each of the demographic questions on the sample data collection form. As a result, the Bureau does not believe it is necessary to include the suggested options on the sample data collection form to address any discomfort by persons that may be completing the data collection form, who are not principal owners, as suggested by some commenters."
_________________________
Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com