Are we permitted to use new applications that contain the revised categories prior to January 1, 2004? Or must we continue to use the old application forms up through December 31, 2003 and convert to the new applications January 1, 2004. The transition rules state if the application is received prior to January 1, 2004 "lenders must collect data on race or national origin using the categories in effect in 2003, ..."

We must use the old applications until 1/1/04.

You answered your own question.

Hmdagal confirmed it. 2003 is 2003. The new form is for 2004 and beyond with the categories appropriate for each. The transition rules handle the interim. But I think you knew that and just wanted confirmation.

Yet another example of how regulators do not live in the real world, and have no idea how challenging it is going to be to make the switch system wide on a specific date.

Thank you all for your responses! I thought that was the answer, but I really wanted confirmation because it's going to be a problem.