Collect Applicant Info on Non-Reportable RE Loans?

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Question:

Should we be collecting applicant information (race, ethnicity, sex) on non-reportable real estate loans? Some examples would be loans against a borrower's home for the purpose of financing college tuition, taking a vacation, purchasing stock, etc. I know we would not include this on our LARs or on the information we send to HUD. I am simply wondering about gathering it for the file. The reason I am wondering if should we have it collected is in case we ever go through a fair lending audit.

Answer:

You would be violating Reg B if you over collect government monitoring information (GMI). You cannot voluntarily collect GMI, it is prohibited by Section202.5 (b). The only exception is for the purposes of a self-test, per Section202.5(b)(1).

First published on BankersOnline.com 7/14/08