GMI on an unsecured credit application

Our unsecured credit applications for home improvement loans does not contain GMI questions and I don't think it is a requirement. In addition, 99% of these applications are received via the internet or fax so we do not see who is applying unless an applicant includes a copy of their ID with their application.

I don't believe there is a requirement to ask for GMI on our unsecured application. However, are we allowed to place GMI questions on this type of credit application if we so desire? Asking for GMI would enable our compliance dept. to monitor for discrimination based on ethnicity, race, sex, marital status, etc.

GMI on unsecured credit is required by neither Regulation B or HMDA. Under what provisions would you be collecting this data?

Asking for GMI would enable our compliance dept. to monitor for discrimination based on ethnicity, race, sex, marital status, etc.

See 1002.5(b). However if you are going to collect this information under the guise of a self-test monitoring program I highly recommend you get your legal council involved.

The FRB had excel tables which could be used for proxies for ethnicity and gender. That might be safer than collecting potentially prohibited information

CFPB had a publication about using publicly available information.
https://files.consumerfinance.gov/f/201409_cfpb_report_proxy-methodology.pdf