We recommend reporting the any GMI that the applicant provides, even if the applicant has checked a box indicating that he or she is refusing to respond to the GMI inquiries. The FFIEC’s HMDA FAQs advise that banks should report partial GMI in this situation:

FFIEC HMDA FAQs, Reporting of partial information:

Question: If an applicant chooses to make selections in one or two, but not all three, fields (ethnicity, race, sex), must the lender report the partial information?

Answer: Yes. A lender must report whatever information the applicant supplies, whether partial or complete. For example, if, on an application submitted by mail, an applicant marks a box indicating the applicant does “not wish to furnish” government monitoring information but supplies some or all of the information, the lender must report the information supplied.