Q: Does my financial institution report the ethnicity, race, and sex of a cosigner?
A: Whether or not a financial institution reports the ethnicity, race, and sex of a co-signer depends on whether the co-signer is a guarantor or a co-applicant. For a guarantor, Instruction 4 to Appendix B to Regulation C, 12 CFR part 1003 states that if a loan or application includes a guarantor, a financial institution does not report the guarantor’s ethnicity, race, and sex. Therefore, if the co-signer is a guarantor according to the terms of the legal obligation as interpreted under applicable law, a financial institution does not report the co-signer’s ethnicity, race, and sex. For a co-applicant, Instruction 5 to Appendix B requires that a financial institution report the co-applicant’s ethnicity, race, and sex.
This Q&A was based on information contained in the Consumer Financial Protection Bureau’s HMDA FAQs Compliance Aid, which may be updated from time to time. This HMDA-related issuance may be found here: