Q: Should a financial institution correct information provided by the applicant for race or ethnicity when the applicant has entered clearly incorrect or inappropriate information on an application?
No. Pursuant to Instruction 8 of Appendix B to Regulation C, 12 CFR Part 1003
, a financial institution reports the ethnicity and race of the applicant as provided by the applicant. Therefore, a financial institution should not correct the race or ethnicity as reported by the applicant, even if the applicant has entered clearly incorrect or inappropriate information.
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 Compliance Aid, which may be updated from time to time. This HMDA-related issuance may be found here: