GMI Clarification Needed

Posted By: Newbie06

GMI Clarification Needed - 02/16/23 09:00 PM

We typically do not run into the situation where the customer doesn't want to provide demographic information. In one case we had the customer indicate, "I do not wish to provide this information" for the Race category. It's my understanding if the application was taken face to face then the lender is to make a choice based on visual observation. Are we then required, for HMDA purposes, to indicate what the customer marked or what the lender decided based on visual observation on the HMDA LAR?
Posted By: hmdagal

Re: GMI Clarification Needed - 02/16/23 09:13 PM

You report what the lender observed. Also, the 3 'visually observed' fields should have code '1'.
Posted By: Newbie06

Re: GMI Clarification Needed - 02/16/23 09:28 PM

hmdagal, I will indicate a 1 for the Race as that was the only area the customer did not want to provide and lender made a visual observation. Thanks for the clarification.