Q: What should a financial institution report for race or ethnicity when the information provided on a written application is illegible?
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.” The rule does not address illegibility. Issues associated with illegible applicant information may be addressed by a financial institution’s compliance management system.
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: