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#685766 - 02/13/07 02:13 PM Incorrect Monitoring Information
bgehres Offline
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Joined: Mar 2005
Posts: 126
We received an application in the mail from one of our current customers. They marked the Race portion as American Indian or Alaskan Native. Since we have dealt with them in the past we know that both of them are white. Should we report what they indicated on the application or what is actually correct?

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#685772 - 02/13/07 02:20 PM Re: Incorrect Monitoring Information bgehres
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
You report what the applicants provided.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#685931 - 02/13/07 04:26 PM Re: Incorrect Monitoring Information bgehres
Truffle Royale Offline

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Just to add a bit...why couldn't someone who appears white be American Indian or Alaskan Native? They know what they are and, as Dan said, you report what they marked. The only time you get to choose is in a face-to-face application where they do not give you the information.

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#686159 - 02/13/07 07:26 PM Re: Incorrect Monitoring Information Truffle Royale
David Dickinson Offline
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David Dickinson
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Central City, NE
When I train on this on this topic I always this is the "I Don't Care" section. You shouldn't care what they put down. If he marks down that he is a she, I don't care. I know that example may seem extreme, but are you going to say "are you sure"?

If you get to closing and the applicant says "why did you mark me down as Indian or Alaskan Native?", you can pull out the original application and show them what THEY said.
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David Dickinson
http://www.bankerscompliance.com

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#689318 - 02/20/07 01:13 PM Re: Incorrect Monitoring Information Truffle Royale
bgehres Offline
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Joined: Mar 2005
Posts: 126
Originally Posted By: Truffle Royale
Just to add a bit...why couldn't someone who appears white be American Indian or Alaskan Native? They know what they are and, as Dan said, you report what they marked. The only time you get to choose is in a face-to-face application where they do not give you the information.
They've marked white before on a HMDA app.

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#689334 - 02/20/07 02:07 PM Re: Incorrect Monitoring Information bgehres
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Quote:
They've marked white before on a HMDA app.


There is no provision in Reg. C to use previously collected information. That allowance is only for Reg. B collection purposes. For Reg. C you report what the applicant provides, and it doesn't matter if they provide different information with every application submitted. You also report information not provided in a mail or telephone request if the information was not provided by the applicant regardless if you have previous information that was reported on a "different" application. Reg. C is an application regulation and you report the applicable information for the application submitted, not previously submitted applications.

I am one quarter American Indian, you would never guess that by looking at me, but it is my prerogative to report my race as an American Indian on any application I submit.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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