We are looking at programatically adding racial information into our marketing customer database. This database is not visable to either deposit or lending staff. We want the information in order to track our success or failure in servicing any particular market and racial group. We want to track results before and after any marketing efforts. We would not allow this information to be used to limit our services to one group over another. Would this be considered OK or a no-no? Does anyone do something like this or had their regulator comment on it?

You are playing with fire unless you are using this info in connection with a Special Purpose Credit Program (see Reg. B).

This sounds like a time bomb! How are you proposing to gather the information? Asking customers? Observation? Both are anathema except for housing-related lending.

Might it not be better to focus on market penetration in census tracts known to have minority residents? Start and maintain a dialogue with community representatives?

Anything but attaching a racial code to names in a database!

If I'm way off base here, someone tell me and I'll recant. But this concept scares the hell out of me.

My hair stands on end when I hear schemes like this. Burns said it best, "The best laid plans of mice and men gang aft aglay."

Why is it any different than keeping racial information on Real Estate loans? You certainly have to be careful how the information is used, and the biggest problem is no matter how positive you use the data, examiners will pick it apart and the smallest hint of an exclusionary process will cause lots of grief.

The only problem I see is you are ahead of your time in trying to do this and being first can get real lonly.

It will also open a pandora's box, as when you start comparing individual customers by race it can easily point out disparities in numbers and percentages being served

I go along with John. Determine where the concentrations of minority populations are, rather that attaching information to individual borrowers. You can easily tract number and dollars to these areas and coupled with other demographic data it can serve your purpose just as well.