The CFPB recently updated its Home Mortgage Disclosure Act (HMDA) FAQs, regarding the reporting of race, ethnicity and sex for applications taken by mail, internet or telephone.
The CFPB addresses the following question:
If a natural person applicant submits a mail, internet, or telephone application under Regulation C but does not provide race, ethnicity, or sex information, what should the financial institution report regarding whether this information was collected on the basis of visual observation or surname?
The CFPB advises that in such a situation, if the institution does not have an opportunity to collect this information during an in person meeting during the application process, it may report either that the information was not collected on the basis of visual observation or surname (code 2) or that the requirement to report this data field is not applicable (code 3). In order to promote the consistency of data across all HMDA reporting institutions, the CFPB suggests, but does not require, that financial institutions use code 2.