Q: The sample data collection form in Appendix B contains, for each applicant, one box for the applicant to indicate "I do not wish to furnish this information." In place of one box for all three fields (ethnicity, race, sex), may a lender place a do-not-wish-to-furnish box in each of the three fields?
A: Yes. A lender may place a box indicating "I do not wish to furnish this information" under each of the three field titles (ethnicity, race, sex) instead of a do-not-wish-to-furnish box that applies to all three fields as a group. Similarly, in a telephone application a lender may wait to read the do-not-wish-to-furnish option until the lender has reviewed the selections in each field, or the lender may decline altogether to state that option expressly so long as (a) the applicant is clearly informed that providing the information, though encouraged, is not required, and (b) if the applicant declines to provide any part of the information, the lender so indicates.