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We have a small amount of minorities in our community versus the surrounding communities. We have an applicant that marked that they are Hispanic or Latino; however, did not mark a race. Should the loan officer complete a visual or do we use the code #7 Non applicable from the HMDA Getting it Right Book? This is a first for us.
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In a face-to-face application if the applicant does not provide all of the monitoring information then you must collect the information based on visual observation or surname. Code 7 is used when the applicant or co-applicant is not a natural person or when information is unavailable because the institution has purchased the loan.
The following guidance might be of assistance to your loan officers:
Classification of Federal Data on Race and Ethnicity
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