2004 HMDA and Ethnicity
Posted By: IUalum
2004 HMDA and Ethnicity - 08/14/03 05:39 PM
I'm confused. First I was told that when an applicant chooses his/her ethnicity (Hispanic or not Hispanic) that he/she still needs to choose a race category (or more than one, if they want). The FFIEC Powerpoint presentation says no; it states that if a person chooses "Hispanic" that they do not need to choose a race. Has anyone else noticed this? It's in the Q&A section at the end of the presentation. If they don't choose a race, what do we report on the LAR? Would that be a code 7 (N/A)? I'm working on training material right now, so anyone else's opinions or comments are welcomed!
Posted By: gone
Re: 2004 HMDA and Ethnicity - 08/14/03 05:45 PM
Whew, I thought I was going crazy when I saw that slide. I was going to pull my notes on it.
I thought the race had to be filled out.
Posted By: Don_Narup
Re: 2004 HMDA and Ethnicity - 08/14/03 06:00 PM
No they do not have to enter a race if they indicate ethnicity is Hispanic. They do need to enter a Race code if not Hispanic.
The confusion comes from the fact that Hispanic is not a Race its an origin, and there are people of different Races that are of Hispanic origin.
By just indicating the ethnicity is Hispanic, then regardles of their race, tracking of loans to Hispanics becomes easier.
Posted By: IUalum
Re: 2004 HMDA and Ethnicity - 08/14/03 06:20 PM
So you're saying it's optional for a Hispanic person to enter a race? Then if they don't choose one on the LAR do you enter code 7 for Not Applicable? You can't leave it blank can you?
Posted By: opie
Re: 2004 HMDA and Ethnicity - 08/14/03 06:21 PM
By just allowing the entering of ethnicity and not requiring race, I don't see how this benefits in data collection. Wouldn't we still have the same information as before the change?
Posted By: hmdagal
Re: 2004 HMDA and Ethnicity - 08/14/03 07:20 PM
At the training session in Chicago last week, we were told that we have to collect both ethnicity and race information. If the application is taken by phone, mail or internet and the applicant chooses not to provide one or the other, we would enter the code for "not provided". If the application is taken face to face the banker would need to provide both ethnicity and race based on visual observation or surname. Unfortunately, they were not able to give any guidance as to what race choice(s) would be appropriate for an hispanic or latino person.
I can't view the powerpoint presentation on the website, but it's supposed to be the same one used at the training session. There's a conversion chart toward the back that we were told is only to be used for the transition period (application taken in 2003, action taken in 2004). Is that what you're looking at?
Posted By: IUalum
Re: 2004 HMDA and Ethnicity - 08/14/03 07:25 PM
Yes, it's probably the same. We were told something similar at a training session a couple of weeks ago. The example of the LAR that's downloadable from the FFIEC site is even more confusing; it shows some examples, and one of them is a Hispanic applicant with a Hispanic co-applicant. The applicant's race is white and the co-applicant's race is black.
Posted By: GreatBlue
Re: 2004 HMDA and Ethnicity - 08/14/03 08:43 PM
USBAVP,
I'm not seeing the slide you referenced. The only slide I see that seems to refer to this issue is, I think, slide 59 which shows the transition rule. What it is showing is that if a customer using a 2003 application chose Hispanic, if final action is in 2004, you would convert that to Ethnicity - Hispanic, and Race - 7 - not applicable.
Is there another slide I'm missing?
Posted By: IUalum
Re: 2004 HMDA and Ethnicity - 08/14/03 08:46 PM
It's slide 31. It doesn't specifically mention Hispanic applicants, but says an applicant does not have to choose both ethnicity and race.
Posted By: Anonymous
Re: 2004 HMDA and Ethnicity - 08/14/03 09:41 PM
I believe it is a play on words. If the applicant answers the Ethnicity question, they still have the option to not answer the race question (ie they don't have to complete it). However, in a face to face interview you will have to complete it based on visual observation; by phone, etc. report it as not provided. This will probably happen a lot.
Posted By: Ski
Re: 2004 HMDA and Ethnicity - 08/15/03 01:47 PM
Yesterday I e-mailed "hmdahelp@frb.gov" with the following question:
Beginning in 2004 we must collect ethnicity and race information on applicants where required. If an applicant selects Code 1 Hispanic or Latino, do they also need to select one of the race categories? Put another way, is Hispanic or Latino just ethnicity or is it ethnicity and race at the same time? Will the FFIEC software allow for the selection of Ehtnicity Code 1 and no Race Code?"
The answers received this morning:
"Race and Ethnicity are mutually exclusive. They are NOT synonymous for purpose fo HMDA reporting. For further information review the documentation available at
http://www.ffiec.gov/RegC.htm"Hope this helps.
Posted By: Don_Narup
Re: 2004 HMDA and Ethnicity - 08/15/03 02:22 PM
I think the confusion lies in that the FRB published a Transition Rules Summary for applications received before 1/1/2004.
On Page 12 it states that:
"The rules in the final comment for converting information on race and national origin collected under the current regulation to the revised categories for ethnicityand
race under the 2002 revisions are provided in tabular format in response to commenters’requests."
It then has a table that shows the "CONVERSION RULES"
and indicates that The current code 4 Hispanic adds a new Ethnicity code of 1 (Hispanic or Latino) and the New Race Category should be reported as code 7 "Not Applicable"
IMO this applies only to applications received prior to 1/1/2004 but originated after 1/1/2004
http://www.ffiec.gov/hmda/pdf/transitionrules.pdf
Again IMO Applications received after 1/1/2004 would indicate both a Race and Ethnicity code.
Posted By: Way Out West
Re: 2004 HMDA and Ethnicity - 08/15/03 04:54 PM
Sorry, everyone, but I've read this thread about 5 times (plus the reg, the supplementary info and the FFIEC training materials) and I'm still confused. Can someone please answer in words of one syllable that an idiot like me can understand? On a face-to-face application taken after January 1, 2004, if an applicant indicates his or her ethnicty is Hispanic or Latino (HMDA ethinicity code 1) and leaves the race portion of the GMI section of the application blank, is it permissible for a lender to leave the race portion of the LAR blank? Yes or no?
If the answer is no, what do we enter? As I understand it, the race field cannot be empty, but as I read it, race code 7 (NA) is NOT to be used on applications taken after 1/1/04 if the applicant is a natural person.
Thanks everyone.
Posted By: Deena
Re: 2004 HMDA and Ethnicity - 08/15/03 05:00 PM
Quote:
On a face-to-face application taken after January 1, 2004, if an applicant indicates his or her ethnicty is Hispanic or Latino (HMDA ethinicity code 1) and leaves the race portion of the GMI section of the application blank, is it permissible for a lender to leave the race portion of the LAR blank? Yes or no?
No
Quote:
If the answer is no, what do we enter?
If the applicant does not provide the information and the application is taken in person, the lender is required to note the data on the basis of visual observation or surname.
Posted By: Don_Narup
Re: 2004 HMDA and Ethnicity - 08/15/03 05:05 PM
Jeffery
I'm not going to pose as the final authority but IMO after 1/1/2004 you will enter both a Race and Ethnicity code for everyone Latino or not.
If you take an app prior to 1/1/2004 but do not close the loan until after 1/1/2004 then you will use the transition rules which calls for a Race code of 7 (NA)if someone indicate their ethnicity is Hispanic/Latino.
The reasoning is the Ethnicity code does not go into effect until 1/1/2004. Applications dated prior to 1/1/2004 have a Race code of 4 indicating Hispanic, but no Ethnicity code.
On 1/1/2004 the Hispanic Race code dissapers, and the Ethnicity code goes into efect.
The transition rules compensate for the change in coding on applications taken prior to the changes going into effect and originating after the changes are in effect.
Posted By: Way Out West
Re: 2004 HMDA and Ethnicity - 08/15/03 06:02 PM
Thanks for a partial answer, but again, what do we enter for race for a person of Hispanic ethnicity if the applicant leaves it blank? Hispanic and what? What if the applicant appears to me to be only Hispanic and nothing else -- which I suspect is going to be the case 99% of the time? I do understand the part about "lender must note based on visual observation or surname," but what if we flat out can't tell what the person's "race" is other than Hispanic? Sorry for being dense here.
Thanks again.
Posted By: IUalum
Re: 2004 HMDA and Ethnicity - 08/15/03 06:22 PM
I'm right there with you Jeff. I can't imagine any of the Hispanics we have around here identifying with ANY of those race categories.
Posted By: hmdagal
Re: 2004 HMDA and Ethnicity - 08/15/03 07:06 PM
That question was asked several times in different ways at the Fed training session a week ago. The presenters did not give us any guidance on what would be an appropriate race category for an hispanic person. They did hint that there may be guidance coming out in the future, but that was about all the information we could get.
Posted By: Sinatra Fan
Re: 2004 HMDA and Ethnicity - 08/15/03 07:58 PM
Here's my semi-frivolous suggestion. Get HUD Secretary Mel Martinez to file a loan application after 1-1-04, and ASK HIM what he wants you to put in the race and ethnicity fields. Then, broadcast his instructions to the BOL universe.
Posted By: GreatBlue
Re: 2004 HMDA and Ethnicity - 08/15/03 08:09 PM
Hmm, that is a puzzle. According to the 2000 Census, of those indicating they were Hispanic,
48% identified their race as White,
2% as Black,
1% as American Indian or Alaskan Native
<1% as either Asian or Pacific Islander
6% as more than one race
42% as some other race - which we all know is no longer an option
That means 42% of Hispanic customers won't see a race listed that they identify with. That sounds like a pretty big problem to me.
Posted By: IUalum
Re: 2004 HMDA and Ethnicity - 08/15/03 08:14 PM
Well, I emailed
hmdahelp@frb with the problem and they wrote me back to tell me I was looking at the slide wrong. Let's see a show of hands--who all here is seeing the slide wrong?
I'm going over to the bar thread on the watercooler forum!
Posted By: Don_Narup
Re: 2004 HMDA and Ethnicity - 08/15/03 08:34 PM
Ok this isn't as difficult as it sounds. If it were I making the decision I would identify the race of Filipinos and anyone in the pacific area of Hispanic origin as Asian/PI.
Those of color from the Caribbean and Some South American countries as Black. Although there are many South Americans that would be considered Caucasian.
Mexicans would be White which I know they won't like but they are mostly a descendent's of a Hispanic European Caucasian stock.
Spaniards from Spain would be Caucasian
Now before the rocks are thrown, please understand that these classification are not new and have always been part of the census
There are only the Races listed. period. Everyone falls into one of those categories. The census lists population by these race categories. Hispanic has never been a race category in the US Census.
What the census has done however is break out of each of the Race categories the number of those in each race category that were of Hispanic ORIGIN.
The new HMDA rule now equates more closely to how the census data is gathered and counted.
Posted By: GreatBlue
Re: 2004 HMDA and Ethnicity - 08/15/03 08:42 PM
Quote:
Well, I emailed hmdahelp@frb with the problem and they wrote me back to tell me I was looking at the slide wrong. Let's see a show of hands--who all here is seeing the slide wrong?
Regardless of what the slide says, or what it is supposed to say, we will still be faced with Hispanic applicants who will mark ethnicity only and refuse to mark race and we will still be required, in a face-to-face interview to pick a race for them.
Don is probably right in his analysis of how to pick the race, but the end result is going to be unhappy customers. When the applicant signs the final application at closing, there will be a race code they didn't pick.
If you ask me, and of course you didn't, I think this whole thing of asking for, recording, and in general categorizing people by race is just plain nuts!!!
Posted By: IUalum
Re: 2004 HMDA and Ethnicity - 08/15/03 08:43 PM
But Don, at the beginning of this thread you said:
Quote:
No they do not have to enter a race if they indicate ethnicity is Hispanic. They do need to enter a Race code if not Hispanic.
Were you strictly talking about during conversion or after 1-1-04?
Posted By: Don_Narup
Re: 2004 HMDA and Ethnicity - 08/15/03 08:49 PM
Yes that is the Transition Rule for applications taken before 1/1/2004 but originated after 1/1/2004.
The rule for applications taken after 1/1/2004 will require a Race and Ethnicity code.
Thats how I'm reading it but the way the regulation has been presented is totally confusing. So I'm hanging my hat on the above but leaving the door open to more clarification from regulators.
We really need Anymous Regulator to jump in here but I haven't seen any post from him/her in awhile.
Posted By: IUalum
Re: 2004 HMDA and Ethnicity - 08/18/03 01:27 PM
OK Folks,
It took some time, but I finally got a straight answer from
hmdahelp@frb.gov.ME: I am very confused about the ethnicity issue. As I first understood it, an
applicant who chooses "Hispanic" as their ethnicity would still be required
to select one or more categories for race. However, according to slide 31
from the FFIEC 2004 HMDA powerpoint presentation, a person is not required
to provide a race designation. Am I reading this wrong, and if so, what is
it referring to? Which line of thought is correct? Thanks.
HMDAHELP: You are reading the slide incorrectly: the first bullet on slide number 31
reads: Applicants must provide both ethnicity and race.
ME: Yes, but the answer to "Applicant must provide both ethnicity and race" says FALSE. So do they or do they not?
HMDAHELP: I understand your question better now. You are required to ask for both
ethnicity and race, however, an applicant is not mandated to provide you
with that information.
ME: So, if I'm understanding this correctly, if the applicant says he is Hispanic but does not provide a race designation, is the lender required to designate a race based on observation or surname, or does the lender not indicate a race at all? Thanks so much for your help!
HMDAHELP: The lender is required to enter all information on the HMDA-LAR as
indicated by the applicant/co-applicant if the application is by mail,
Internet or telephone. If the application is in person and the applicant
only provides partial information, the lender is required to supply the
information not provided by the applicant based on visual observation or
surname.
So there you have it. Hope this helps. Thanks to everyone for their input on this very confusing issue.
Posted By: Andy_Z
Re: 2004 HMDA and Ethnicity - 08/18/03 01:29 PM
We appreciate the follow up.
Thanks Usbavp. I, like you, had read the question wrong (it is a little trick). So, we must have an ethnicity AND race on all applicants, but the applicant does not have to provide them.
Now we are back to my original question: What race is a Hispanic person? I know Don Narup said the following, but it really makes me nervous:
Quote:
If it were I making the decision I would identify the race of Filipinos and anyone in the pacific area of Hispanic origin as Asian/PI.
Those of color from the Caribbean and Some South American countries as Black. Although there are many South Americans that would be considered Caucasian.
Mexicans would be White which I know they won't like but they are mostly a descendent's of a Hispanic European Caucasian stock.
Spaniards from Spain would be Caucasian
Posted By: IUalum
Re: 2004 HMDA and Ethnicity - 08/18/03 02:55 PM
David, I know what you mean. This whole thing makes me uncomfortable.
Posted By: Don_Narup
Re: 2004 HMDA and Ethnicity - 08/18/03 03:14 PM
Quote:
it really makes me nervous:
Yes it will take a different mind set as we have never been asked to make a Race call on a person of an ethnic origin before.
IMO the difficulty is not in making the call its getting over the so called political correctness of anything that has to do with race. Most people are uncomfortable to even discuss race with another person for fear they may be accused of something.
Remember you did not make the rules, and the definitions for Race and Ethnicity have been used for years. The problem is we never paid attention to them in the past, and now are dealing with them as something new, which they really are not.
There is no audit or examination of your call. The key is not really what race a person of Hispanic/Latino origin is. It's the fact that their Ethnicity has been selected. This segment of the population is not discounted, as no matter what race is selected that are counted through the Ethnicity code.
All that has transpired here is that the count is now aligned with the way census data has been collected.
Quote:
Most people are uncomfortable to even discuss race with another person for fear they may be accused of something.
Exactly! In fact, I'm concerned about teaching this at the ABA Compliance School in October. Andy's my school adviser. Maybe I can play sick and then he'll have to teach it. 
(just kidding Andy).
Posted By: Andy_Z
Re: 2004 HMDA and Ethnicity - 08/18/03 05:18 PM
Cough, cough. I'm feeling a little under the weather too.
Posted By: Anonymous
Re: 2004 HMDA and Ethnicity - 08/18/03 06:10 PM
For estimating race when not provided by the applicant, why not use the OMB Race Definitions as a guide?
Posted By: Don_Narup
Re: 2004 HMDA and Ethnicity - 08/18/03 08:03 PM
Here they are:
The minimum categories for data on race and ethnicity for Federal statistics, program
administrative reporting, and civil rights compliance reporting are defined as follows:
-- American Indian or Alaska Native. A person having origins in any of the original peoples of North and South America (including Central America), and who maintains
tribal affiliation or community attachment.
-- Asian. A person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian subcontinent including, for example, Cambodia, China, India, Japan,Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and Vietnam.
-- Black or African American. A person having origins in any of the black racial groups of Africa. Terms such as “Haitian” or “Negro” can be used in addition to “Black or African American.”
-- Hispanic or Latino. A person of Cuban, Mexican, Puerto Rican, South or Central American, or other Spanish culture or origin, regardless of race. The term, “Spanish
origin,” can be used in addition to “Hispanic or Latino.”
-- Native Hawaiian or Other Pacific Islander. A person having origins in any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands.
-- White. A person having origins in any of the original peoples of Europe, the Middle
East, or North Africa.
Thanks for the definitions Don, but realistically, how is a loan officer going to know this info? If the applicant does not provide the race info, a LO is not going to say "what is your origin?" I'm meeting a lot of resistance on this as we train loan officers on the new HMDA rules.
Posted By: Andy_Z
Re: 2004 HMDA and Ethnicity - 08/18/03 08:32 PM
I might revert to a wise post here recently that said to the effect, "based on visual observation they looked like an under-served category identified in recent analysis".
Posted By: Don_Narup
Re: 2004 HMDA and Ethnicity - 08/18/03 11:12 PM
IMO the race issue is not an issue, as making the best guess on personal observation does not mean it has to be an absolute. There is a big Tolerance range.
As bankers we get into it must be 100% correct and everything must balance mode. In this case, as with other demographic information, we need to accept it doesn't have to be, nor is it, an exact.
The most important item to keep in mind when you have to explain it, is that the analysis and counts of Hispanic/Latino is now based on Ethnicity rather than race. It doesn't matter what Race they state, or the officer selects, getting the ethnicity code correct IMO is more important.
Loan Officers do not have to ask "What is your origin" How about "Are you of Hispanic or Latino Origin" Its a Yes or No question.
I am not defending the fact that this and what some others would consider intrusive questions are being asked. Its here and not going to change, so try and look at what the purpose of the change was. Having Hispanic as a Race previously was incorrect and gave false data. This new arrangement now aligns the data with current census information and allows for better and more accurate analysis reporting.
Posted By: RFitzpatrick
Re: 2004 HMDA and Ethnicity - 08/19/03 05:46 AM
I attended the PBS HMDA seminar last week in Seattle, and asked the same question. They also stated the best way was to print out the OMB definitions and give them to our lenders during training, then they can use it to decide or show the customer, and hope for a good guess.
Posted By: Anonymous
Re: 2004 HMDA and Ethnicity - 08/19/03 12:55 PM
Especially since a 'guess' is pretty much all will be. As Dan stated, it is not something we have to be precise with. Some of the applicants are going to have to guess themselves. Just be happy we don't have to require proof of origin.
Posted By: CarlD
Re: 2004 HMDA and Ethnicity - 08/19/03 04:44 PM
I told my children, whenever they are asked, they should declare their heritage as American Indian. In fact, they are 1/16th.
The local school districts seemed very interested, but I know of no specific benefit or damage that ensued.
Posted By: MackenzieS
Re: 2004 HMDA and Ethnicity - 08/19/03 09:24 PM
Quote:
IMO the race issue is not an issue, as making the best guess on personal observation does not mean it has to be an absolute. There is a big Tolerance range.
I have read this post all the way through and I think there is merit in being sensitive to the lenders hesitation. If I am a customer and I apply for a loan by phone, walkin, however, and all of a sudden someone starts asking me not only what ethniticity I am but what my race is, do you think my first thought isn't going to be the fact that it may be a mark against me? Look at it from the customers point of view.
Next, Don mentioned that there is a lot of Tolerance for error here because lenders are going to mark what they personally feel will fit the bill. Okay, back to the purpose of HMDA, it is to help the govt identify to whom we are lending and where we are lending our money to see if we are doing our jobs to support our communities and to assist govt in determining federal programs as well. If banks are reporting incorrect information on a consistent basis, who does this benefit?
Don mentioned that the concept is not new, its not, but when you start probing individuals about their race and ethniticity it can be perceived very negatively by the customer. As one who has to conduct the training, I am not very excited about this, I think it is vague and confusing. I don't think lenders should have to go pull out a chart and go "Hmmmm.....okay, lets seeeeee heeerrree , you must beeee ummmm, a Pacific Islander!" -What?!
It amazes me sometimes that people get paid to come up with this stuff. Well, then again, I get paid to keep up with it huh? 
Posted By: CarlD
Re: 2004 HMDA and Ethnicity - 08/19/03 10:07 PM
Here's a likely scenario.
The applicant is asked about his/her race or ethnicity. He hesitates to answer.
The interviewer applies police logic - why is he hesitating? What is he trying to hide?
The applicant may not be aware of his right to decline to answer. And he won't know the minimal impact that the answers probably have on the application.
Posted By: Deena
Re: 2004 HMDA and Ethnicity - 08/21/03 02:46 PM
Quote:
The applicant may not be aware of his right to decline to answer. And he won't know the minimal impact that the answers probably have on the application.
You are required to disclose to the customer that (1) the information is requested by the Federal government, not the bank, 2) that the customer does not have to answer the questions, 3) if the customer chooses not to answer, you, the lender, are required to provide it for them, and (4) providing the information - or not providing it - has no impact on the application. If you have explained this to the customer, rather than just asking for the information without explaining it, the customer will know the voluntary nature of the questions and may be more likely to cooperate. That doesn't mean it's easy or that the customer will like it. But, if they understand that you're going to fill it out for them anyway, they might fill it in themselves.
Posted By: Wonderland
Re: 2004 HMDA and Ethnicity - 08/22/03 04:08 PM
I've been checking in periodically on this thread as it progresses, and just read it all the way through again today. The race/ethnicity issue has bothered me a LOT ever since it came up.
Who are the customers that will be disturbed/offended/confused by the questions? NOT "white" men and women. Who WILL be offended? Anyone who checks Hispanic who doesn't see him or herself listed in one of the race categories. I think we miss the boat when we focus on what WE should check if the Hispanic applicant declines to check a race box because he/she feels none of them apply. That's very easy -- as has been pointed out, where's the audit on this, if we have to fill in the blanks based on visual observation.
What we should be focusing on instead is training our lending officers on how to talk to Hispanic customers, to prevent this whole issue from becoming a public-relations nightmare for our individual institutions. We have to learn how to talk about race in a society that prefers to pretend to be race-blind. Heck, in California right now we are faced with a ballot initiative in October that would prohibit the gathering of EXACTLY this kind of data. It just might pass, and won't that be fun, to explain to the borrower that federal regs out-rank state law, so we still have to ask these questions.
So, I'm interested in any resources for developing this training that anyone might suggest. For instance: any local Hispanic Chamber of Commerce, an owner of a Spanish-languange radio or television station, any bank staff of Hispanic or Latino heritage. Etc. Any thoughts?
Posted By: Don_Narup
Re: 2004 HMDA and Ethnicity - 08/22/03 04:34 PM
Quote:
Anyone who checks Hispanic who doesn't see him or herself listed in one of the race categories.
People of Hispanic/Latino origin have always had a race category. Follow the OMB guidelines. While there may be a few who "think" hispanic is a race, IMO this is not going to be a problem. Remember they are counted based on the Ethnicity code, The race code does not eliminate them from being included in an analysis, and they are not left out of anything.
We can speculate ourselves into a fetal position. Being armed with factual information, and a positive attitude, will cause this change in data collection to become old hat within a very short time.
I have difficulty understanding why this is a problem as I am asked very frequenty by people I meet "What nationality is "Narup" without any hesitation on their part. Get the first few data collections behind and lets see what the attitude is then.
Posted By: Kansayaku
Re: 2004 HMDA and Ethnicity - 08/22/03 04:42 PM
I am glad that HMDA goes into more detail than many other forms.
Granted, it may be over-kill, but it is definitely better than those that have only "white, african-american, hispanic, and native american".
As a Jamaican friend of mine informed me, he fit into none of the categories listed. And another friend of mine who is white and of South African heritage could be classified as two of them.
Posted By: Anonymous
Re: 2004 HMDA and Ethnicity - 08/25/03 04:59 PM
Responding to definitely better :
I have a library of examples where the bureaucracy thinks it needs more data so it can it add one more decimal of precision.
On careful inspection, the prevailing precision was not being used. The binary go/no-go decisions could have been made with far less data.
Posted By: Anonymous
Re: 2004 HMDA and Ethnicity - 10/21/03 03:18 PM
Anyone heard anymore information on this?
Posted By: Anonymous
Re: 2004 HMDA and Ethnicity - 10/22/03 03:22 PM
I will tell you. I am Hispanic...and when I saw the changes to HMDA, I thought Hmmmmm....if I were applying for credit, I'd select Ethnicity of Hispanic or Latino. Then I looked at race and thought......none of those apply to me. I was equally confused that I did not have a race. I believe that quiet a few Hipanics or Latinos will not check anything under the race category because they don't apply (or appear to not apply)
Posted By: Don_Narup
Re: 2004 HMDA and Ethnicity - 10/22/03 04:35 PM
Folks, Race does apply to those of Hispanic origin. I guess my question is why do you think it doesn't. What makes those of Hispanic origin a different Race? Certainly Language and geography doesn't do that. Perhaps knowing why Hispanics believe themselve to be of another race will help resolve the issue.
IMO the problem is Hispanic was listed previously in the RACE selection box for HMDA purposes and people got the idea from that, that Hispanic was a Race.
The real change here is that HMDA data will now be collected the same way as the census bureau collects race information. The census bureau has always assigned a race to those of Hispanic/Latino origin as defined by the Office of Management and Budget. These definations have been posted on BOL threads.
Basically if you are Mexican you are of the White Race and have an Ethnicity of Hispanic/Latino.
If you look at census demographics by Race you do not see Hispanic as a listed Race. What you do see is a breakout from all the race categories of what the population of those in the Race categories are of Hispanic Origin.
If you leave the Race category blank then a loan officer is going to fill it in for you. Instead of fighting the issue, researching and satisfy yourself that it really is a help and not a henderience or slight to anyones race or origin, this needless concern could be put to rest. It does not effect the Hispanic/Latio communities in any way.
Posted By: Nanwa
Re: 2004 HMDA and Ethnicity - 10/22/03 04:53 PM
Posted By: Anonymous
Re: 2004 HMDA and Ethnicity - 10/22/03 05:02 PM
I think their efforts in all of this data collection is faulty in some respect. If I applied for credit strictly over the phone or on Internet and did not check etnicity or race, the loan officer makes the choice on his/her observation of my married surname (which is german). This would be totally incorrect as I am Hispanic. I do realize this gets us more in line with how the census bureau captures information. I agree that the Hispanic or Latino communities would not be offended. I am not offended in any way...just confused
My birth certificate listed my race as white. However, every form I have ever filled out regarding race gave a catagory for "Hispanic." It would be easier for the race category to have one category called "Human" (for human race)!
Posted By: Lestie G
Re: 2004 HMDA and Ethnicity - 10/22/03 05:03 PM
What it's coming down to in our markets is what people think or believe personally - not what the OMB and census definitions have always been. Most Hispanics I have polled (employees and friends) consider themselves NOT WHITE. No matter what the underlying uses and meanings of the data we gather is, we still have to figure out how to explain this to a Hispanic person who considers themselves NOT WHITE.
Also, many Mexicans are descended from Spaniards, but many are also descended from groups native to North or South America - so we would be remiss to check white on all these people. There aren't any easy answers!
Posted By: Anonymous
Re: 2004 HMDA and Ethnicity - 10/22/03 05:10 PM
I would like to add that I have not met a white person yet that considers a hispanic person white! Or like you said a hispanic person who considers themselves white. I don't consider myself white. Your are right that it does boil down to what people think or believe.
Posted By: RVFlyboy
Re: 2004 HMDA and Ethnicity - 10/22/03 05:55 PM
Quote:
I think their efforts in all of this data collection is faulty in some respect. If I applied for credit strictly over the phone or on Internet and did not check etnicity or race, the loan officer makes the choice on his/her observation of my married surname (which is german). This would be totally incorrect as I am Hispanic. I do realize this gets us more in line with how the census bureau captures information. I agree that the Hispanic or Latino communities would not be offended. I am not offended in any way...just confused My birth certificate listed my race as white. However, every form I have ever filled out regarding race gave a catagory for "Hispanic." It would be easier for the race category to have one category called "Human" (for human race)!
First, if you applied in a purely telephone application, the lender would not be required (and in fact would be prohibited) to make your race and ethnicity selection for you if you opted to not provide it.
Although you are Hispanic in terms of ethnicity, your birth certificate is correct - your race is white. It's just like Don says - you'd check both the Hispanic ethnicity box and the White race box. Someone like Sammy Sosa would be of Hispanic ethnicity and Black race.
Posted By: Don_Narup
Re: 2004 HMDA and Ethnicity - 10/22/03 07:22 PM
Quote:
I have polled (employees and friends) consider themselves NOT WHITE.
Ok lets try it this way The following are THE ONLY RACE categories on the planet. They differentiate a people by definable characteristics. You have to be one of these, there are no others in the world, regardless of what a personal wish or belief may be.
White
Black
Asian Pacific Islander
American Indian
Can you see where existing race categories have diffetent genetic characteristics. So what genetic differences exist in the hispanic origin population that makes them different enough to be of another race, or not one of the ones established.
In your opinion what makes Hispanic origin people different from any of the defined race categories.
Don't confuse a NATIONALITY with race. Race has nothing to do with culture, language and location, similarities. If that were the case then there would also be a German, French, Swedish etc as Races?
Posted By: Nanwa
Re: 2004 HMDA and Ethnicity - 10/22/03 07:59 PM
Polska!
Posted By: Princess Romeo
Re: 2004 HMDA and Ethnicity - 10/22/03 09:49 PM
I think the confusion is because the "white" category is so all-encompassing and includes groups that feel they have nothing in common. A person of Middle-Eastern heritage is considered "white", and so is someone from Norway. The majority of Hispanics are white, as are most folks from Italy, Russia, England, Germany, Latvia, Finland, Greece, and so on.
The area that has me confused is the sub-continent of India. Are persons from there considered "white" or "Asian"?
Quote:
The area that has me confused is the sub-continent of India. Are persons from there considered "white" or "Asian"?
Good question. I would vote "white".
Here's my poll results:
1. I have a Hispanic friend named Joe (Jose). He completed the 2004 GMI by marking Hispanic/Latino and male. When I asked him for race he said he would not complete it. He added that if I marked white, he would consider that an insult.
2. My friend TJ is from the Dominican Republic. He marked
Hispanic/Latino and male. When I asked him to mark a race, he said he didn't think he should, but if he had to he would mark black.
Posted By: Don_Narup
Re: 2004 HMDA and Ethnicity - 10/23/03 02:06 AM
Here are the official Office of Management and Budget definations of Races. In answer to the question, The sub continent of India is considered to be Asian. Please note the defination of Hispanic/Latino can be from specific NATIONALITIES regardless of race.
American Indian or Alaska Native. A person having origins in any of the original peoples of North and South America (including Central America), and who maintains
tribal affiliation or community attachment.
-- Asian. A person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian subcontinent including, for example, Cambodia, China, India, Japan,Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and Vietnam.
-- Black or African American. A person having origins in any of the black racial groups of Africa. Terms such as “Haitian” or “Negro” can be used in addition to “Black or African American.”
-- Hispanic or Latino. A person of Cuban, Mexican, Puerto Rican, South or Central American, or other Spanish culture or origin, regardless of race. The term, “Spanish
origin,” can be used in addition to “Hispanic or Latino.”
-- Native Hawaiian or Other Pacific Islander. A person having origins in any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands.
-- White. A person having origins in any of the original peoples of Europe, the Middle
East, or North Africa.
Posted By: waldensouth
Re: 2004 HMDA and Ethnicity - 10/23/03 01:15 PM
Personally, I would like to see an "All-American Mutt" category. The bean counters in our government keep trying to divide us up and stick us into neat little categories that just don't fit.
Posted By: Don_Narup
Re: 2004 HMDA and Ethnicity - 10/23/03 02:45 PM
Quote:
bean counters in our government keep trying to divide us up and stick us into neat little categories that just don't fit.
From these posts I think its the opposite. Census folks established just 5 Race categories many many years ago which have not changed. Now the popular sentiment is to create more by further dividing into more segregated groups, which seem to be more along lines of nationality.
Its become very obvious that there needs to be a clear understanding of the definitions of Race, Ethnicity, and Nationality,and how they are applied in demographics.
Frankly, it doesn't matter if a Hispanic origin person selects White or any other Race, as there is an analysis category that will count Hispanic/Latinos separately regardless of what race is indicated. So like Blacks, Asian, American Indian, Hawaiian/and Pacific Islander, those of Hispanic/Latino origin are well considered in any analysis of exclusionary or discriminatory practices.
I have posted on several occasions my belief that if banks would use the demographics available, they could expect to see dramatic increases in profitable. From these posts I can see why its not done, which is because there is not enough understanding on what they mean or how to use them. Anyone want a class?
Posted By: swiggles
Re: 2004 HMDA and Ethnicity - 10/23/03 04:31 PM
Whew!!! I just read this whole thread in one sitting!! My brain has turned into noodles.
Here's a question of more of a technical or procedural nature. On a typical real estate loan application, there is first, the statement regarding the fact that the information is required by the Federal Government...blah, blah, blah (read Deena's statement above). The first selection under that is a box for the applicant to indicate that he/she does not wish to furnish the information. Sooooo, how would the customer indicate that he/she does not wish to furnish only the race information?
Normally, when the customer indicates that he/she does not wish to furnish the information, the interviewer completes the information on the application and signs it. If the loan officer were to do this when only the race information is left blank, it would then appear that the applicant completed it.
Any ideas?....or am I making way too much of this?
Posted By: Wonderland
Re: 2004 HMDA and Ethnicity - 10/23/03 09:22 PM
There are really at least two distinct threads going here. There's the question about what the reg says we have to do, given the race and ethnicity categories provided, with no "other" category. No one is arguinge that we can or even SHOULD try to do anything to change the categories and definitions. We all can and will do the best we can to comply with the reg.
The other thread, the more "knotty" one, is to answer the questions and concerns of our good Latino/Hispanic customers who are legitimately confused, because they have always considered their race to be what is now defined as ethnicity, and they don't see their race listed as an option. We would be doing our respective employers a disservice if we are perceived as saying "you're wrong; Hispanic is NOT a race. See, it says so here in the definitions." We are not in the business of proving to people that they are wrong about themselves, no matter what the regs say. That's the quickest way I know to lose customers. "The customer is always right" is the first rule of good customer service. So this is our challenge, and the topic of the second thread: how do we train our people to talk to customers about this without driving the customer away by implying that they are wrong about what they have always believed to be true?
Posted By: Princess Romeo
Re: 2004 HMDA and Ethnicity - 10/24/03 12:03 AM
In the "How do you not offend your Hispanic/Latino customer" thread, I'm tending toward the following:
Mr. Lopez, I understand how you feel about these categories, and apologize if you feel offended. The government has completely changed the manner in which they require banks to collect this information. Yes, it does seem bizaare that Hispanic is no longer a race but is now an ethnicity, and that you must now indicate if you are a White/Hispanic, Black/Hispanic, etc., or a combination of races and Hispanic. We are as confused by this as you are, but we have no choice but to indicate at least one of this categories even if you do not wish to.
If you find this offensive, may I suggest that you write to your congressional representative and let him or her know how you feel.
Posted By: Don_Narup
Re: 2004 HMDA and Ethnicity - 10/24/03 12:22 AM
Quote:
Yes, it does seem bizaare that Hispanic is no longer a race but is now an ethnicity,
IMO this reinforces the mistaken fact that at one time Hispanic was considered to be a race, which it never was. It also stirs up the government is meesing with me attitude.
Just leave this part out and I think its fine.
Posted By: Princess Romeo
Re: 2004 HMDA and Ethnicity - 10/24/03 04:38 AM
Don, I predict this will go over like a lead balloon in the Inland Empire.
Of course, that's the only area from which I received Privacy Notice complaints even though our notice said we weren't sharing.
And it's the area that people will still claim they are citizens of the Republic of California and therefore not required to have a SSN.
Kid gloves I tell ya...
Posted By: MackenzieS
Re: 2004 HMDA and Ethnicity - 12/29/03 08:53 PM
Okay, I am resurecting this post due to some research that I found out on the OMB's website. I am getting ready to conduct my Reg B & C training tomorrow and I felt like I needed to go to the source to find out about the Hispanic Ethnicity/Race dilemma.
It appears in testing conducted through the OMB, prior to the 2000 Census, they targeted groups to test various forms for obtaining race/ethnicity to find which would produce the greatest responses (in a nutshell). It appears they consciously put the ethnicity question first because it reduced nonresponses from the Hispanic population tested. Also, that the majority of the Hispanic respondents reported Ethnicity as Hispanic or Latino and Race as White.
Maybe this is not earth shattering to some of you, but at least it gives us a comfort level of the way the majority of the applicants may view themselves and for those applicants that do not wish to complete the government monitoring information maybe it will give us more of a comfort level in what to record.
U.S. Census Bureau Here is the website if you want some good reading before you go to sleep at night!
Posted By: Princess Romeo
Re: 2004 HMDA and Ethnicity - 12/29/03 10:25 PM
I got a rather strong reaction from Hispanic acquaintances when I told them the government now considers Hispanic to be an ethnicity and not a race. These particular acquaintances really saw themselves as a group distinct from "white" people.
Posted By: Don_Narup
Re: 2004 HMDA and Ethnicity - 12/29/03 11:02 PM
I guess I don't get it, as I have never seen any reference to Hispanic as a Race, and have a problem with understanding why the belief it is or was. Could it be that bankers are incorrectly giving credence to it being a Race by referring to Hispanic/Latino as a Race?
We still need to get the idea across that Hispanic is a term, on par with Italian, Irish, German, French, etc. as an Origin. It is not a slight or demeaning circumstance suddenly brought on by the government. The government census bureau has always collected the data as an origin and not as a race. Hispanics have always been counted and included in one of the races.
The choice bankers have is to educate or infuriate
Posted By: Princess Romeo
Re: 2004 HMDA and Ethnicity - 12/30/03 02:56 AM
Don,
I don't know if its bankers so much as just a general consensus, especially among persons who identify themselves as Hispanics. Listen to almost any Latino stand-up comic, and you will hear lots of references to weird stuff that "white people" do, and the many differences between Latinos, Whites, Blacks, Asians, etc.
Or at least that's what I've heard.
Posted By: Anonymous
Re: 2004 HMDA and Ethnicity - 12/30/03 04:07 PM
Anyone found good descriptive definitions for race and ethnicity?
Posted By: MackenzieS
Re: 2004 HMDA and Ethnicity - 12/30/03 04:13 PM
I did.
Categories and Definitions Go down about 3/4ths of the page
Posted By: Anonymous
Re: 2004 HMDA and Ethnicity - 06/14/04 10:49 PM
As the question relates to those of Mexican or Central American decent, I am inclined to think that they would identify most closely to "American Indian or Alaska Native". Being of a mixed Hispanic decent myself, I have to believe that someone of Central American decent is going to have a certain amount of Mayan, Aztec or Incan blood. Those are, by definition, "Native Americans" since America refers to more than just the United States. America encompasses North, Central and South America.
The problem that Hispanics have with these questions stems from the fact that this sort of information is not gathered in their home countries. Maybe there is a lesson to be learned here. How are we supposed to become more tolerant and "color blind" if we continue to categorize and segregate ourselves?
Quote:
How are we supposed to become more tolerant and "color blind" if we continue to categorize and segregate ourselves?
Excellent point. Unfortunately, I don't have an answer.
Posted By: Lestie G
Re: 2004 HMDA and Ethnicity - 06/15/04 03:25 PM
Quote:
The problem that Hispanics have with these questions stems from the fact that this sort of information is not gathered in their home countries.
In my part of the country - a large percentage of the Hispanic community have lived in this country for hundreds of years. Much longer than any 'white' people. I'm sure they don't really identify with their Spanish ancestors, or Mayan, or Incan, or Apache, or English, or whatever - they just consider themselves Hispanic. That's usually the dilemna when our customers try to fill out that information. I agree - trying to categorize people is not a very good way to move toward total racial equality!
Posted By: Don_Narup
Re: 2004 HMDA and Ethnicity - 06/15/04 04:57 PM
Quote:
I am inclined to think that they would identify most closely to "American Indian or Alaska Native".
To use Alaska Native or American Indian the pereson must have a tribal affiliation BUT per OMB Central and South American "INDIANS" can be classified as American Indian. the original American Indian or Alaska Native include "ORIGIAL" peoples from Central and South America. That doesn't mean all Hispanics should be classified as American Indian.
So in some instances you can use American Indian or Alaska Native and stiil indicate Ethnicity as Hispanic or Latino.
Posted By: Anonymous
Re: 2004 HMDA and Ethnicity - 08/13/04 08:29 PM
Quote:
I'm confused. First I was told that when an applicant chooses his/her ethnicity (Hispanic or not Hispanic) that he/she still needs to choose a race category (or more than one, if they want). The FFIEC Powerpoint presentation says no; it states that if a person chooses "Hispanic" that they do not need to choose a race. Has anyone else noticed this? It's in the Q&A section at the end of the presentation. If they don't choose a race, what do we report on the LAR? Would that be a code 7 (N/A)? I'm working on training material right now, so anyone else's opinions or comments are welcomed!
Posted By: Dan Persfull
Re: 2004 HMDA and Ethnicity - 08/13/04 08:41 PM
The applicant is not required to choose any category at all.
They may choose Ethnicity and leave the other categories blank, or any combination thereof.
In face to face applications you are required to choose for them based on visual observation and surname if they leave the category blank. If it's a telephone, mail, or Internet application you would report what the applicant furnished and report Not Provided for what they did not.
Posted By: Anonymous
Re: 2004 HMDA and Ethnicity - 08/13/04 08:44 PM
Applicants are not required to provide their ethnicity and race information. If you see the applicants during the application process and they have not provided the information, then the lender must note the ethnicity and race information based on visual observation and/or surname if the action taken date is on or after 1/1/04. If the application was received in 2003 and the action taken date occurs in 2004 and the applicant selected Hispanic on the government monitoring information section then you would use code 1 for Ethnicity to indicate Hispanic and then you would use Code 7 for race under the transition rules if you did not see the applicant.
Posted By: someone else
Re: 2004 HMDA and Ethnicity - 08/13/04 09:24 PM
I was under the impression that code 7 was only to be used for non-entities. Shouldn't it be marked as code 6 - Not Provided?
Posted By: hmdagal
Re: 2004 HMDA and Ethnicity - 08/13/04 10:04 PM
If the application was taken in 2003, it would fall under the transition rules, and then you would use a '1' for ethnicity and '7' for race if they indicated hispanic on the application.
Posted By: someone else
Re: 2004 HMDA and Ethnicity - 09/02/04 08:17 PM
Sorry to bring up this thread again , but I have another twist on this scenario:
What if the application is taken face-to-face but the applicant obviously lies about their race/ethnicity/gender. Is the LO to take the information given by the applicant, even though visual observation confirms that the info is incorrect?
Posted By: swiggles
Re: 2004 HMDA and Ethnicity - 09/02/04 08:25 PM
You must use what the applicant indicates.
I wouldn't touch the GMI when the applicant fills it out in front of you. The loan officer might ask "are you sure you marked the appropriate boxes (or something more tactful), but if that is what they wanted, let it stand.
Posted By: hmdagal
Re: 2004 HMDA and Ethnicity - 09/02/04 08:30 PM
The only thing I would change from what the applicant completes would be the sex (after just being told by my examiner that even if John and Mary Smith said that they were both males, I should indicate that Mary is a female).
Posted By: Lestie G
Re: 2004 HMDA and Ethnicity - 09/02/04 08:31 PM
I wouldn't even change that - things are not always as they seem!
I'm with Lestie. I see nothing in HMDA that supports what that examiner stated. HMDA and ECO give the applicant the right to fill out whatever they want.
Posted By: Dan Persfull
Re: 2004 HMDA and Ethnicity - 09/02/04 08:56 PM
I agree with David and Lestie. The only time you report the information based on visual observation in a face to face application is when the applicant does not furnish the information.
Posted By: Sinatra Fan
Re: 2004 HMDA and Ethnicity - 09/03/04 01:08 PM
I'm not disagreeing with Lestie, David, or Dan; we have handled similar situations the same way.
But think about the effect of such actions. We are then knowingly reporting inaccurate information, in accordance with the regulation, to the Federal Reserve Board. They will then take this inaccurate information, disseminate it to the public, and use this inaccurate information to make decisions and evaluations.
Add to this correct reporting of inaccuracies the other errors reported by those who are not scrupulously fastidious about their data integrity, and you start to wonder exactly how valid the HMDA information is. It reminds me of Mark Twain's statement that there are three types of lies: lies, damnable lies, and statistics.
Posted By: Jay-Risk
Re: 2004 HMDA and Ethnicity - 09/03/04 02:14 PM
For somebody like myself who is not close to this issue daily, but who is involved in the risk evaluation of the process, it appears excruciating to see so many people with good intentions suffer through this. The problem is exascerbated by a level of vagueness and typical unclear regulatory implementation which can tend to become too buraucratic, and which can turn off senior management and the board.
Customers primarily contact us about HMDA-reportable mortgage loans (firsts, refinances, or home improvements) through telephone calls to our call center. When a consumer decides to submit an application (and become a customer), the call center representative after gathering all of the applicant data that constitutes an application then briefly explains the Reg C requirement to gather race, gender and ethnicity data and the customer is told that the bank's decision regarding approving or declining a loan is not in any way influenced by the applicant's preference not to disclose their race, gender, or ethnicity. The applicant is then asked, "May I ask your race, gender and ethnicity?" If the customer says yes, we ask ethnicity, race and gender; if they say no, we code it 3-6-3 and nothing else is done. Our analysis of reporting to date, at least for our institution, is that if a customer does not want to provide ethnicity, then the chances are almost always that they don't want to move ahead and discuss race and gender. At that point, we code the session a "3-6-3". We don't hound the customer once they indicate any displeasure with revealing ethnicity. We stop asking at that point. Our process has recently gone through a rigid examination, and with flying colors.
I'm seeing a tendency for some people here to get way too bogged down in process. The object is to make loans and, optionally, to obtain the race, gender and ethnicity data if possible, and without alienating the customer or losing the deal. The goal isn't to be good data collectors but not make loans.
Quote:
We are then knowingly reporting inaccurate information, in accordance with the regulation, to the Federal Reserve Board.
You don't know if you are taking inaccurate info. How do you know if he is really a she, that he is black, white, or purple? The point is that they can fill it out any way they want. The instructions make that very clear. No where has the FRB every said "over see this process to make sure the info. is accurate". I believe that the FRB knows that they will get some bogus info, but they are willing to pay that price vs. having a loan officer change what an applicant says.
Posted By: Sinatra Fan
Re: 2004 HMDA and Ethnicity - 09/03/04 03:12 PM
David, I
do know the difference between a male and a female (at least as long as we're not lending to Michael Jackson or RuPaul).
Posted By: hmdagal
Re: 2004 HMDA and Ethnicity - 09/03/04 03:36 PM
And our examiners point was that if the property is titled as "husband and wife", and the mortgage is signed that way, we can be certain that one person is male and the other is female. From a common sense point of view, I know he's right, and chose not to make an issue of it (now, if he had cited it as an error, that might have been different, but this was just a friendly visit). If there is only one applicant, or the applicants are not married to each other, we continue to report as shown on the application.
But show me anywhere where it says you should alter the GMI provided. It isn't there. The examiners made this up and it is not supported in the Regs.
Posted By: hmdagal
Re: 2004 HMDA and Ethnicity - 09/03/04 04:22 PM
Your absolutely right, but I tend to agree with his logic. Therefore, I didn't push the issue.
Posted By: Anonymous
Re: 2004 HMDA and Ethnicity - 09/03/04 05:41 PM
What do you enter for Vulcans?
Quote:
What do you enter for Vulcans?
There is no "other" race anymore, so this isn't possible. We used to see all sorts of weird stuff.
Posted By: Dan Persfull
Re: 2004 HMDA and Ethnicity - 09/07/04 02:28 PM
Quote:
The object is to make loans and, optionally , to obtain the race, gender and ethnicity data if possible,
This is not an option, it's a regulatory requirement.
As an applicant I have the right to choose any designation I wish. It is not the lender's, or anyone else's place to judge what I choose is right or wrong. The lender's responsibility is to collect the information from the applicant and report the data accurately.
I have 1/4 Native American heritage, and I can legally designate myself as an American Indian, however my physical features do not reveal the Native American heritage. Therefore, if I chose American Indian, and you changed it to White based on your observation you would be reporting inaccurate information.
Posted By: JSD
Re: 2004 HMDA and Ethnicity - 09/07/04 02:49 PM
Not about ethnicity, but along the same lines...What do you do when you see that the gender was incorrectly marked & reported. For example, the applicant's name is Elizabeth and some how it was checked male on the application, but all other references are to husband and wife and the pronouns were appropriate, would you correct the application and LAR or just leave it as the wrong gender. (I know that in some cases it can be same sex marriage, etc. but this was not the case.)
Posted By: swiggles
Re: 2004 HMDA and Ethnicity - 09/14/04 01:54 PM
Quote:
What do you enter for Vulcans?
If an applicant were to write this in on the application in a face to face interview, I would consider that the applicant does not wish to provide the information and then make my "guess" based on visual observation and sur name. In a phone interview, if the person insists verbally that he or she is vulcan, I would indicate that the person does not wish to provide the information. A person that would make such a statement either:
1. Really does NOT want to provide the info; 
OR
2. The person REALLY thinks he or she IS a vulcan.
Hmmmm.....in the case of number 2, I wonder if we can take this into consideration when making the loan decision ............just kidding. 
Posted By: KAT
Re: 2004 HMDA and Ethnicity - 09/14/04 05:17 PM
We had a customer with a female name and male checked and the co-applicant had a male name with female checked. Because the interview was face to face we left it the way it was. The FDIC stated that it was done correctly because it was a face to face interview.
Posted By: RR Becca
Re: 2004 HMDA and Ethnicity - 09/15/04 02:43 PM
I need help on what to do with this one, please...
The lender took a secondary market application that the borrower had filled out by hand and signed but didn't fill in the GMI section. There is also a computer generated application in the file WITH the GMI filled in, but not signed. The original application is marked "face to face". So do I take the info from the CG application and accept it as lender provided based on the face to face? I'm confused as to how to report this.
I'm leaning towards hang the lender...
Posted By: Truffle Royale
Re: 2004 HMDA and Ethnicity - 09/15/04 02:49 PM
I usually call the lender and sweetly tell him/her that if it's marked face-to-face, it has to be filled in so could he please give me the information. I fill in the info in red ink and mark it as "per telephone conversation with ___ on ____, 2004". This satisfied the feds when they were here this Spring.
I've yet to have a second offense from any LO I've called and chided about this.
Posted By: RR Becca
Re: 2004 HMDA and Ethnicity - 09/15/04 03:01 PM
Thanks bjp! I spoke with the LO's assistant and she promised to fuss at him for me. One more question <a bit brain dead this morning> under "type of purchaser" on a withdrawn secondary market, the loan was neither declined nor sold - so which option do we mark?
Posted By: Truffle Royale
Re: 2004 HMDA and Ethnicity - 09/15/04 04:02 PM
0-Loan was not originated or was not sold incalendar year covered by register.
Posted By: RR Becca
Re: 2004 HMDA and Ethnicity - 09/16/04 02:40 PM
Thanks a bunch!