My bank is in the process of converting our branch platform system with a new application. In the new account opening process, in one of our fields where we can enter information we would have the ability to collect home ownership/renter information. (NOTE: Currently, we are not asking our consumers/customers for this information.)

If we wanted to ask this if a consumer/customer owns or rents when they opened a new deposit account, are there any legal implications we should be aware of, i.e., is this ok for us to ask? Thanks for your help.

There are no restrictions on asking this question.

There is something called the "law of unexpected consequences" (or something like that).

Let's say that a particular Census Tract in your area has a "very high" (whatever that means) percentage of minority residents. Coincidently, it has a very low percentage of owner-occupied housing.

Because of the low percentage of owner-occupied housing, you do not advertise mortgage products in that area. Now, prove that there was no disparate impact on the minorities.

I agree with you Al, but I am finding it hard to relate your comments to the original question. Retaining whether a customer is a renter or homeowner does come in handy when target marketing your own customers - one receives refinance materials while the others receive new mortage loan materials. Gathering this information is not prohibited, but I guess theoritically it could be used in a desparate impact scenerio.

What you are talking about doing is "householding" which is a great way of finding out who your customers are and what kind of products and services they might be interested in. And, (in my state anyway) whether someone is a homeowner is a matter of public record. In fact, our e-commerce guru told me that we have the ability to access our county assessor's database to complile mailing lists for loan promotions etc. (personally, I think that is a little scary!). But there should be no reason to not be able to ask at account opening whether someone rents or owns.

When I was a branch manager for two big banks, we did alot of "customer profiling". This was our way of finding out what the customer needs were. This also enable us to "cross-sell". There is nothing wrong with either as long as it is done with the "good" intention of the customer in mind. I strongly believe in both and to be honest was very good at both. My branch and I, personnally, were usually "top" performers each quarter (not to tute my horn). If you are going to do something and be good at it, you must believe in it. Can you tell I miss it?

Word of advice, train the staff.

Opinions are mine not my employer