Same Loan Application, Only Different

November 2, 2016

Last month the Bureau of Consumer Financial Protection (CFPB) quietly approved a revised and redesigned Uniform Residential Loan Application (URLA) for 2017 to allow for the collection of more information about the ethnicity and race of loan applicants.

With some exceptions, Regulation B § 1002.5(b) generally prohibits a creditor from inquiring about the race, color, religion, national origin, or sex of an applicant or any other person in connection with a credit transaction.  However, Regulation C, as amended by 2015 Home Mortgage Disclosure Act final rule, will require financial institutions to permit applicants to self-identify their race and ethnicity beginning January 1, 2018.  However, before that date, such inquiries will not be required by Regulation C or allowed under Regulation B.

The redesigned URLA and accompanying CFPB staff opinion will allow a financial institution, as of January 1, 2017, to permit applicants to self-identify their race and ethnicity without being in violation of Regulation B § 1002.5(b). 

Read the complete CFPB here.

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