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#51013 - 12/27/02 10:19 PM HMDA cleanup - phone ap
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
I am cleaning up a HMDA mini-mess and I couldn't find this exact situation in any old posts. I have some loans that were entered as refusing to provide race/national origin in a phone ap but gender is noted. It seems to me that if race is a 7, gender should be a 3...both meaning info not provided in a phone or mail ap.

I am using logic on this as I have never seen that mentioned anywhere. Is my approach correct?

Thanks.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
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Lending Compliance
#51014 - 12/27/02 11:16 PM Re: HMDA cleanup - phone ap
hmdagal Offline
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hmdagal
Joined: Dec 2002
Posts: 3,812
The LAR should reflect what is marked on the application. It is possible for the applicant to provide gender, but not race information.

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#51015 - 12/28/02 04:45 AM Re: HMDA cleanup - phone ap
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
But these are phone aps, not written...and every single one shows no info provided for race/origin yet reflects the gender. When I started to see it over and over, I began to question whether it was even correct to have (in a phone ap) does not wish to report race, but was willing to report gender.

If it is legitimate, then I will leave it. The fact that I keep seeing it over and over makes me suspicious that they are marking gender based on voice/name. That of course is a training issue going forward. I suppose I can just leave it, and address the issue going forward that if they say they do not wish to provide in a phone ap, do not guess.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#51016 - 12/29/02 08:47 PM Re: HMDA cleanup - phone ap
Lucy Griffin Offline

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Lucy Griffin
Joined: Nov 2000
Posts: 1,544
You probably have lenders that are guessing at gender based on first names and voices. Since the information is noted on the application, you should probably report it. However, it's worth asking regulators whether they want such guessing going on.

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#51017 - 01/02/03 08:33 PM Re: HMDA cleanup - phone ap
Suwannee Offline
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Suwannee
Joined: Jun 2002
Posts: 641
Florida
I agree that it appears strange that all of the loans are indicated like this. I think you need to have a short training session with the people taking the applications. They obviously do not realize the importance given by certain trade groups for obtaining the correct information. A smart examiner will catch this in an exam.
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#51018 - 01/02/03 08:37 PM Re: HMDA cleanup - phone ap
Suwannee Offline
Platinum Poster
Suwannee
Joined: Jun 2002
Posts: 641
Florida
I agree that it appears strange that all of the loans are indicated like this. I think you need to have a short training session with the people taking the applications. They obviously do not realize the importance of obtaining the correct information. A smart examiner will catch this in an exam.
_________________________
When you lose, don't lose the lesson.

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#51019 - 01/02/03 11:17 PM Re: HMDA cleanup - phone ap
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
Thanks for the replies. Yes, we will be training, training, training.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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