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#2153147 - 11/10/17 09:15 PM DI on Telephone Apps
TMatt87 Online
Diamond Poster
TMatt87
Joined: May 2011
Posts: 1,984
Idaho
A colleague just returned from a conference, and apparently they taught that for telephone applications, the LO only had to read the borrower the aggregated categories rather than list off all the subcategories. I haven't heard anything like this. I'm about to train a hundred LOs that they have to read the whole page on phone apps, so I'm sure I'll be real popular, so I want to make sure I'm accurate.

Thanks!
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#2153151 - 11/10/17 09:28 PM Re: DI on Telephone Apps TMatt87
Monster Offline
Platinum Poster
Joined: Sep 2015
Posts: 500
From the Small Entity Compliance Guide...

To ask an applicant for ethnicity, race, and sex information regardless of whether the Application is taken in person, by mail, by telephone, or on the internet. A Financial Institution cannot require the applicant to provide this information.
When a Financial Institution requests ethnicity and race information from an applicant under the HMDA Rule, it must offer the applicant the option of selecting more than one ethnicity and race and must permit the applicant to self-identify using aggregate categories and disaggregated subcategories. When a Financial Institution requests the applicant’s ethnicity and race, the aggregate categories must be broken down into disaggregated subcategories. For example, the aggregate category of Hispanic or Latino must be broken down into the subcategories of Mexican, Puerto Rican, Cuban, or Other Hispanic or Latino. Similarly, the Asian and Native Hawaiian or Other Pacific Islander categories also must be broken down into their respective disaggregated subcategories.
An applicant must be permitted to select one or more race or ethnicity subcategories even if the applicant has not selected a race or ethnicity aggregate category. For example, an applicant could select Mexican even if the applicant has not selected Hispanic or Latino.

It would be great if your colleague/conference was correct, but I haven't seen anything supporting that... yet.

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#2153153 - 11/10/17 09:31 PM Re: DI on Telephone Apps TMatt87
TMatt87 Online
Diamond Poster
TMatt87
Joined: May 2011
Posts: 1,984
Idaho
Thanks Gila. I figured it was wishful thinking.
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