Time for S’More learning: Collecting disaggregated HMDA data

first_img 6SHARESShareShareSharePrintMailGooglePinterestDiggRedditStumbleuponDeliciousBufferTumblr Hi, Compliance Friends. We are currently enjoying some wonderful fall weather here in Washington, DC.With the pending HMDA changes, some credit unions have been uncertain about the regulatory authority to be currently collecting the disaggregated age, race and sex data. This blog presents the crux of the conflict with Regulation B, which implements the Equal Credit Opportunity Act, current HMDA guidance, and a credit union’s options for collecting disaggregated data including how that may impact its implementation of the new HMDA rules.Regulation BGenerally, Regulation B (Equal Credit Opportunity Act) prohibits credit unions from inquiring into an applicant’s race or ethnicity. However, Regulation B permits inquiries for monitoring purposes in connection with self-testing or HMDA (Regulation C) reporting. continue reading »last_img

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