Home Mortgage Disclosure Act (HMDA)/Reg C

Regarding ethnicity and race what do we choose if the application is taken over the phone and we cannot see the applicant?

It is only necessary to collect ethnicity and race on an application taken via telephone if the applicant provides the ethnicity and race (also sex) after the person taking the application has provided the verbal disclosure regarding why this data is collected (this verbal disclosure is required on a phone application), if the applicant elects to provide this data. Identifying whether this data was obtained via visual observation or surname is only required for applications taken in person or via electronic media which includes a video component, or an application begins in a different manner but is completed at some point via either of these methods (face-to-face, whether in person or via video transmission).

<A chart (see category - Collecting Ethnicity, Race & Sex (Chart)) of the specific requirements for documenting ethnicity, race and sex is provided for your use in determining whether or not to document this data via visual observation or surname, based on the manner in which the application is taken, is provided below.

Citation(s):Appendix B (Instructions #1, 2, 3, 10, 11, 12, 13)