CFPB HMDA FAQ - Should a financial institution correct spelling or other errors made by the applicant in providing ethnicity and race information in the free form text fields?

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Q:   Should a financial institution correct spelling or other errors made by the applicant in providing ethnicity and race information in the free form text fields for Other Hispanic or Latino, American Indian or Alaska Native, Other Asian, or Other Pacific Islander?
 
A:  No. Instruction 8 of Appendix B to Regulation C, 12 CFR Part 1003 states that a financial institution “must report the ethnicity, race, and sex of an applicant as provided by the applicant.” Therefore, a financial institution should not correct the race or ethnicity as reported by the applicant, even to correct spelling or other errors.

For general information on the collection and reporting of applicant information, see section 2.4 of the HMDA Small Entity Compliance Guide and Appendix B to Part 1003—Form and Instructions for Data Collection on Ethnicity, Race, and Sex.
 
 
This Q&A was based on information contained in the Consumer Financial Protection Bureau’s HMDA FAQs document, version 4, dated July 28, 2020, which is updated from time to time.  This HMDA-related issuance may be found here:  https://files.consumerfinance.gov/f/documents/cfpb_HMDA_frequently-asked-questions.pdf
 

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