2018 HMDA - new rules for gathering Ethnicity/Race

Posted By: KerriAnnF

2018 HMDA - new rules for gathering Ethnicity/Race - 09/21/17 03:11 PM

Under the amended and final HMDA rule, applicants now have additional choices available to them for "self-identification" purposes with regard to their (ethnicity/race). the revised rule has linked "new" sub-categories to existing "Main" categories, and, even offers an additional "other" category which applicant can choose from to self-identify further if they do not wish to select form the list. Appendix B states that (for a telephone application), the information on the collection form should be stated "orally". My question is this: Are creditors required to read ALL of the available sub-categories linked to each main category before asking the applicant to identify their Ethnicity or Race, or, is it acceptable to "only" read the "sub-categories" linked to a main category already selected by the applicant?. For Example: If an applicant is asked whether they are (Hispanic/Latino OR: NOT Hispanic/Latino) and they state that they are NOT Hispanic/Latino, is it OK "NOT" to read any of the (Hispanic) "sub-category" choices since they stated they are NOT Hispanic when they selected a main category? Its understood customer needs to know they have available choices but I'm needing to confirm if the HMDA rule is requiring a lender to read all "main" categories followed by a list of "all" of the available "sub" categories" up front before the customer responds or are we only required to read the sub-categories linked to a "main" category already selected by the applicant?
Posted By: Kathleen O. Blanchard

Re: 2018 HMDA - new rules for gathering Ethnicity/Race - 09/21/17 03:19 PM

I would be concerned about not presenting all options.

They can select both Hispanic/Latino and Not Hispanic/Latino.

They can select sub-categories and not select a major aggregate category.

By shortening what is said, they won't have all options.
Posted By: RR Joker

Re: 2018 HMDA - new rules for gathering Ethnicity/Race - 09/21/17 03:23 PM

This is going to be so much fun. crazy
Posted By: JWills, CRCM

Re: 2018 HMDA - new rules for gathering Ethnicity/Race - 09/21/17 04:01 PM

I am so looking forward to it. NOT!!!
Posted By: Ski

Re: 2018 HMDA - new rules for gathering Ethnicity/Race - 09/21/17 06:00 PM

I am helping with setting up training for the 2018 rule.

I've been dealing with HMDA for about 36 of the 38 years I've been in banking.

I am retiring on 12/28/2017 so I'm not going to worry about it on 1/1/2018.
Posted By: RR Joker

Re: 2018 HMDA - new rules for gathering Ethnicity/Race - 09/21/17 06:02 PM

That's just mean, Ski. frown
Posted By: Sinatra Fan

Re: 2018 HMDA - new rules for gathering Ethnicity/Race - 09/21/17 06:18 PM

I am very, very jealous, Ski. But congratulations on your impending retirement!
Posted By: RR Joker

Re: 2018 HMDA - new rules for gathering Ethnicity/Race - 09/21/17 06:30 PM

What ^^^ said...absolute congrats!!!
Posted By: Skittles

Re: 2018 HMDA - new rules for gathering Ethnicity/Race - 09/21/17 06:41 PM

Me, too. Congratulations on your upcoming retirement!!!
Posted By: hmdagal

Re: 2018 HMDA - new rules for gathering Ethnicity/Race - 09/21/17 06:45 PM

Congratulations!