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#2174201 - 04/19/18 12:50 PM Both "do not provide" and race choices selected?
Dazed&Confused2 Offline
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Joined: Nov 2015
Posts: 14
When a borrower completes some of the demographic information concerning their race and also selects the box which says they do not wish to provide information, what is reported? Everything the applicant checked even if it is contradictory or do we not provide the information because they have checked the box stating they don't wish to provide. This may have been asked before, but I can't find the answer. Any guidance appreciated.
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#2174202 - 04/19/18 12:54 PM Re: Both "do not provide" and race choices selected? Dazed&Confused2
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
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Bloomington, IN
You report what the applicant provided and report not provided for what they left blank.
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#2174217 - 04/19/18 01:33 PM Re: Both "do not provide" and race choices selected? Dazed&Confused2
swiggles Offline
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swiggles
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Dazed.....are you saying that for the same category (for example....race), the applicant indicated a race AND checked "not wish to provide?"
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#2174227 - 04/19/18 01:49 PM Re: Both "do not provide" and race choices selected? Dazed&Confused2
GTS333 Offline
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Joined: Jun 2010
Posts: 257
Appendix B

13. When an applicant provides the requested information for some but not all fields, you report the information that was provided by the applicant, whether partial or complete. If an applicant provides partial or complete information on ethnicity, race, and sex and also checks the “I do not wish to provide this information” box on an application that is taken by mail or on the internet, or makes that selection when applying by telephone, you must report the information on ethnicity, race, and sex that was provided by the applicant.
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#2174306 - 04/19/18 05:49 PM Re: Both "do not provide" and race choices selected? Dazed&Confused2
David Dickinson Offline
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David Dickinson
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Central City, NE
If you are saying they chose a race and chose "I do not wish . . . " for race, you should report the race(s) they chose. IOW, ignore the "I do not wish . . ."
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http://www.bankerscompliance.com

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#2244493 - 10/22/20 08:45 PM Re: Both "do not provide" and race choices selected? David Dickinson
Compliance NABW Offline
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Is this still the current understanding of this, or do you attempt to report both "I do not wish" and the Race selected? I don't see reporting both as an Edit in the 2020 FIG.

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#2244503 - 10/23/20 03:23 AM Re: Both "do not provide" and race choices selected? Dazed&Confused2
David Dickinson Offline
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David Dickinson
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Posts: 18,762
Central City, NE
I don't believe you can report both "I do not wish" and a race.
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#2244516 - 10/23/20 01:17 PM Re: Both "do not provide" and race choices selected? Dazed&Confused2
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
FWIW I would report the selected race, sex and ethnicity and sort it out if it was questioned in an exam.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2244524 - 10/23/20 02:26 PM Re: Both "do not provide" and race choices selected? David Dickinson
Compliance NABW Offline
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Joined: Oct 2015
Posts: 1,669
It seems like it may be allowable for Applicant 1 per the FIG . . . it's hard to say for sure. #13 in Appendix B could be interpreted to mean do both, but logically it makes more sense to ignore "I do not wish to provide." If logic were a key thing in GMI though, somebody wouldn't be able to check American Indian and then free text "Nigerian" as their enrolled tribe, lol, and have that be reported on the LAR.

Thank you both for your input.
Last edited by Compliance NABW; 10/23/20 02:26 PM.
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#2244529 - 10/23/20 02:50 PM Re: Both "do not provide" and race choices selected? Dazed&Confused2
hmdagal Offline
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hmdagal
Joined: Dec 2002
Posts: 3,841
The following edits seem to indicate that you can't report both: V628 and V638.

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#2244531 - 10/23/20 03:03 PM Re: Both "do not provide" and race choices selected? hmdagal
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I was looking at that and you have to read it very carefully. It doesn't prohibit it for the same applicant.

{4) If Race of Co-Applicant or Co-Borrower: 1 equals 6, 7, or 8, then Race of Co-Applicant or Co-Borrower: 2; Race of Co-Applicant or Co-Borrower: 3; Race of Co-Applicant or Co-Borrower: 4;andRace of Co-Applicant or Co-Borrower: 5 must be left blank.}

If race of Co-Borrower: 1 equals 6, then race of Co-Borrower :2-5 must be left blank. It doesn't say anything about Co-Borrower :1 not having the ability to have another code marked. Similar language with V631 and V635.

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