I am being told by an outside auditing source that if an applicant puts Male under the sex portion of the application, and their name is Sheila, that I am to report “female” because they “should have put” female. They say it is an error and I should report female on the LAR. My argument is this…I have to put whatever whatever is on that application. I can not change it based on my opinions of who they actually are. If the customer where to put that they are white, african american, male and female, I am to report it that way. I can not CHANGE what is on that application. PLEASE ADVISE
Based on the information you have given, I believe you need to report what the customer marks, even if it seems like it doesn’t truly represent the person. It could be an accident or there could be a reason that it is marked the way it is. Either way, you should report what the person marked. On the other hand if a bank employee completed the section based on visual observation and they marked it incorrectly by mistake, in that situation I think you should correct the information to reflect what was actually observed.