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#2262170 - 11/05/21 02:42 PM HMDA - Ethnicity
William Offline
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Joined: Jun 2018
Posts: 3
Applicant provided ethnicity -1. Hispanic or Latino, 11. Mexican. 14. Other Hispanic or Latino and written on the freeform "Guatemalan". but on the reporting, we input 1. Hispanic or Latino, 14. Other Hispanic or Latino, 11. Mexican and the freeform "Guatemalan". Question, is the order number matter and the 14. Other Hispanic or Latino must be before the freeform?

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#2262181 - 11/05/21 04:14 PM Re: HMDA - Ethnicity William
Dan Persfull Offline
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Welcome to BOL.

If you use the CFPB reporting tool then there is a specific order for entering the information.

Ethnicity of Applicant or Borrower: 1 Ethnicity of Applicant or Borrower: 2 Ethnicity of Applicant or Borrower: 3 Ethnicity of Applicant or Borrower: 4 Ethnicity of Applicant or Borrower: 5 Ethnicity of Applicant or Borrower: Free Form Text Field for Other Hispanic or Latino - it repeats for Co-applicant or Co-borrower.

If you are asking about an internal collection form then I'm not sure what order you collect it in would matter as long as you report it in the correct order so the CFPB's data checking routines can accurately verify the information.

There is a model collection from in the 2021 GIR on page H-24.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2262182 - 11/05/21 04:21 PM Re: HMDA - Ethnicity William
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2262184 - 11/05/21 04:29 PM Re: HMDA - Ethnicity Dan Persfull
William Offline
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Joined: Jun 2018
Posts: 3
Hello Dan,

Thank you for the information. On the CFPB regulation, it doesn't clarify the reporting must in sequential numbers in order. is that matter or as soon as we reporting the correct data that will be fine?

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#2262189 - 11/05/21 04:52 PM Re: HMDA - Ethnicity William
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
You may have to check with your software vender that submits your data.

I use the CFPB's Lar Formatting Tool (https://ffiec.cfpb.gov/tools/lar-formatting) and you have to enter the data in a specific order.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2262195 - 11/05/21 05:37 PM Re: HMDA - Ethnicity William
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
OK, I think I might better understand your quesiton.

1. Hispanic or Latino, 11. Mexican. 14. Other Hispanic or Latino and written on the freeform "Guatemalan". but on the reporting, we input 1. Hispanic or Latino, 14. Other Hispanic or Latino, 11. Mexican and the freeform "Guatemalan". Question, is the order number matter and the 14. Other Hispanic or Latino must be before the freeform?

In the CFPB Lar Formatting tool the information would be entered as:

Column R - Ethnicity of Applicant or Borrower 1 - 1
Column S - Ethnicity of Applicant or Borrower 2 - 11
Column T - Ethnicity of Applicant or Borrower 3 - 14
Column U - Ethnicity of Applicant or Borrower 4 - left blank
Column V - Ethnicity of Applicant or Borrower 5 - left blank
Column W - Ethnicity of Applicant or Borrower: Free Form Text Field for Other Hispanic or Latino - Guatemalan

But you entered it as:

Column R - Ethnicity of Applicant or Borrower 1 - 1
Column S - Ethnicity of Applicant or Borrower 2 - 14
Column T - Ethnicity of Applicant or Borrower 3 - 11
Column U - Ethnicity of Applicant or Borrower 4 - left blank
Column V - Ethnicity of Applicant or Borrower 5 - left blank
Column W - Ethnicity of Applicant or Borrower: Free Form Text Field for Other Hispanic or Latino - Guatemalan

I'm not sure if that would cause a validity error or not in how the CFPB's validity routines checks the expected information in each column/row.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2262196 - 11/05/21 05:44 PM Re: HMDA - Ethnicity Dan Persfull
William Offline
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Joined: Jun 2018
Posts: 3
Hello Dan,

I went to the https://ffiec.beta.cfpb.gov/filing/2021/institutions and upload the data to test and validate the HMDA data. it shown no error found. so I think it doesn't matter the sequential numbers in order, as long as the data is on those 5 fields.

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