Collecting GMI on Loans Not Reported on HMDA LAR

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Question:

We have chosen to not report HELOCs on the HMDA LAR, but we do collect GMI on all home loan applications. I cannot find in Reg C that we are prohibited from collecting the GMI data for loans not reported on the HMDA LAR. Is collecting this data on loan applicants against any regulation and if so, could you please site the regulation?

Answer:

You won't find the prohibition in Reg C. You will find it instead in Reg B. Section202.5(a)(2) provides that you are allowed to collect information about race, sex and ethnicity to comply with both HMDA and with Reg B 202.13. Otherwise, Section202.5(b)(2) prohibits collecting information about an applicant's race, color, religion, national origin or sex.

First published on BankersOnline.com 4/21/08