Selecting race for the applicant

Question: As a follow-up question, what do we do if the applicant checks Hispanic for ethnicity but does not think that any of the choices for race apply. Do we have to select a race for the applicant? How should we do this?

Answer: When an applicant refuses to indicate race, the old rules about mandatory completion apply. This means that, if the application is face-to-face, the loan officer should complete the information based on visual observation of the applicant. When doing this, the measurement is not whether the loan officer guessed correctly about the applicant's racial ancestry. The measurement is that the loan officer should note what he or she observes. It is possible that the loan officer would check "Asian" when the individual sitting before them is a member of a Native American Tribe. However, for purposes of evaluating discrimination, we care as much about what the loan officer thinks as about the accuracy of that perception.

Copyright © 2003 Compliance Action. Originally appeared in Compliance Action, Vol. 8, No. 6, 6/03