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#2186583 - 07/24/18 02:22 PM ECOA/HMDA GMI
Cheli Offline
Platinum Poster
Cheli
Joined: May 2013
Posts: 919
Well, here's a first for me...

Applicant submitted a complete application via internet.
They selected "I Do Not Wish To Furnish" as well as Not Hispanic, Male, White...
So, does my FI report BOTH on the Final 1003 and for HMDA reporting?

Thank you-

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Lending Compliance
#2186673 - 07/24/18 09:49 PM Re: ECOA/HMDA GMI Cheli
Bville Offline
Diamond Poster
Bville
Joined: May 2001
Posts: 1,282
Out West
Based on this from Appendix B to Reg C, I would report just what the applicant selected and not "I do not wish to furnish"

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.

I can't speak to what investors want to see on a final 1003.

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#2186684 - 07/25/18 01:31 AM Re: ECOA/HMDA GMI Cheli
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I would report not Hispanic, white, male.
_________________________
David Dickinson
http://www.bankerscompliance.com

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