During a recent HMDA review, I found that no demographic information form was being collected for entity borrowers. When questioning lending staff they indicated they didn't get one since there was no "N/A" box to mark so it was assumed that the collection was only for individuals (natural persons). Our HMDA worksheet allows for the lender to mark N/A so input support reports correctly on the LAR. In researching Reg C (1003.4(b)), it states collection of the data for the applicant or borrower in accordance with Appendix B. Appendix B 7. refers to reporting the data as N/A on an applicant that is not a natural person, but doesn't specifically say anything about collecting the data.

So my question is this . . . . Do you have a demographic information form in the file for non-natural person applicants, and if so, what box do you mark since there is no "N/A" on the model form? OR, do you NOT fill out a demographic information form for non-natural persons and just report as N/A on the LAR?

What demographic information would you collect from a non-natural person for HMDA reporting? A non-natural person has no race, sex, etc.

So in other words, I (and you) answered my own question and we don't need the demographic information form in file for entities. I knew I was making this way harder than it needed to be Thanks Randy!