We sell all of our FHA mortgages to an investor. What responsibility, if any, do we have for the Equal Access Rule? Should our procedure reflect that we do not discriminate based on sexual orientation or gender identity when taking a FHA mortgage application? Is there some data collection and reporting that we are required to do?
You should update your policies and procedures as indicated. There is no data collection required, other than HMDA data, if your bank is subject to HMDA.