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Isn’t it a violation of 12 CFR 1003.4(b) if a bank does not request government monitoring information in writing using the wording from Appendix B of the regulation, via an application or separate form for a HMDA reportable loan application?
You seem to be correct, but I believe reviewing Appendix B might clear up any further questions you might have. The wording provided is part of a sample form that uses model language; that being said I have never seen any other language used by a creditor.
https://www.gpo.gov/fdsys/pkg/CFR-2013-title12-vol8/pdf/CFR-2013-title12-vol8-part1003-appB.pdf
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