We have in the past not reported home improvement loans. Obviously 2004 we will.

My question is... an application taken in 2003 for home improvment... the GMI was not collected. Loan closed in 2004. The loan officer had the customer complete the a data collection form that included ethnicity. The conversion rules do not really apply.

What do I do?

Puzzling question, my first guess is to select Ethnicity-3 and Race-6 which are the "Not provided..." responses. This is the closest to the truth.

Any one else?

If something is in the file, I don't think you can "not know" it. I would report the information that was collected.

You would report even the ethnicity? I did not think we were suppose to ask that question on applications taken in 2003?

The loan officer did collect that information in 2004 prior to closing. So we do know it.

I'm not sure if the experts would agree, but I would. The GMI form wasn't filled out until 2004, so I don't think there would be an issue with collecting the data.

I have rethought this and have another idea. Since you can collect the information anytime before the loan closes, depending on the policy of your bank, I would report what is on the GMI. (Thanks hmdagal) It will be interesting to see what the edits do with this information.

For example, if you hand out an application in 2003 and receive it in 2004, the edits get all out of whack on this and the transition rules don't really work. I feel sure that we will see some other edit issues as we check our LAR.

(hmdagal got in again before I finished this, so it seems that I finally got on the same page)

It's a good thing this transition period won't last long!

Have you tried entering it into the FFIEC HMDA program? When you do and try to enter the ethnicity information for an application received in 2003, it comes up with a validity error saying that an application date < 1/1/2004, Ethnicity must = 4, Not Applicable. You must use the transition rules.