Academic journal article ABA Banking Journal

When Phone Customers Won't Give HMDA Data. (Home Mortgage Disclosure Act)

Academic journal article ABA Banking Journal

When Phone Customers Won't Give HMDA Data. (Home Mortgage Disclosure Act)

Article excerpt

Q. What should a bank do, when taking a Home Mortgage Disclosure Act (HMDA) application by telephone, if the applicant refuses to provide the data that the government wants?

A According to 12 CFR 203, Appendix A, V, D, 2 :

"Mail, Internet, or Telephone Applications. All loan applications, including applications taken by mail Internet, or telephone, must use a collection form similar to that shown in appendix B regarding race or national origin and sex. For applications taken by telephone, the information in the collection form must be stated orally by the lender, except for information that pertains uniquely to applications taken in writing. If the applicant does not provide these data in an application taken by mail, Internet or telephone, enter the code for 'information not provided by applicant in mail or telephone application' specified in paragraphs V.D.3. and 4. of this appendix."

Also note after Jan. 1, 2004, you must take the following into account, from 12 CFR 203, Appendix A, I, D, 2, (Pending):

"Mail, Internet, or Telephone Applications. …

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