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#2126589 - 04/17/17 07:14 PM Disaggregated Race & Ethnicity
Compliance Newbie Offline
Member
Joined: Jan 2015
Posts: 79
"Only an applicant may self-identify using the disaggregated ethnicity and race categories"

If a Financial Institution takes an applicant by phone is the FI allowed to ASK for this disaggregate information?

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#2126625 - 04/17/17 09:33 PM Re: Disaggregated Race & Ethnicity Compliance Newbie
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Yes, in fact you must. The point is the lender can't pick sub-ethnicity & sub-race categories.
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David Dickinson
http://www.bankerscompliance.com

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#2126656 - 04/18/17 12:36 PM Re: Disaggregated Race & Ethnicity David Dickinson
Compliance Newbie Offline
Member
Joined: Jan 2015
Posts: 79
Thanks David

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#2127325 - 04/20/17 06:30 PM Re: Disaggregated Race & Ethnicity Compliance Newbie
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
The financial institution is required to ask. As David said, if the application is face to face and the applicant declines to provide the information, the FI only selects from the aggregate categories.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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