Q: How are the HMDA provisions regarding the collection and reporting of applicant information being adjusted?
A: Effective January 1, 2018 for data collected in or after 2018 (to be reported in or after 2019) –
For data collected in or after 2018, the 2015 HMDA Rule amends the requirements for collection and reporting of information regarding an applicant’s or borrower’s ethnicity, race, and sex.
First, the 2015 HMDA Rule adds a requirement to report how the institution collected the information about the applicant’s or borrower’s ethnicity, race, and sex. A financial institution will report whether or not it collected the information on the basis of visual observation or surname. 12 CFR 1003.4(a)(10)(i). Financial institutions are required to collect information about an applicant’s ethnicity, race, and sex on the basis of visual observation or surname when an applicant chooses not to provide the information for an application taken in person.
Second, financial institutions must permit applicants to self-identify using disaggregated ethnic and racial subcategories and must report disaggregated information applicants provide. However, the 2015 HMDA Rule does not require or permit financial institutions to use the disaggregated subcategories when identifying the applicant’s ethnicity and race based on visual observation or surname. The 2015 HMDA Rule includes a new sample data collection form in appendix B that provides the required aggregated categories and disaggregated subcategories for ethnicity and race. Appendix B to Part 1003.