GMI Method Question

Good afternoon everyone,

I was hoping to get an assist interpreting an aspect of GMI method that I've wondered about. In terms of visual observation and surname, why would surname only be included for in-person apps since it's not a visual cue?

Thanks!

the question reads: Was (___) collected on the basis of visual observation or surname.
Visual observation is one thing.
Surname is another separate thing that has nothing to do with visual.
EITHER the observer is basing his best guess on the applicant's surname (ex: Gonzalez) OR he's basing it on what he sees by looking at the applicant.

Truff hit that nail on the head, " If the applicant(s) chooses not to provide the information or any part of it, that fact shall be noted on the form. The creditor shall then also note on the form, to the extent possible, the ethnicity, race, and sex of the applicant(s) on the basis of visual observation or surname."

Note the word "OR" in that quote from 1002.13.