I would include the form then. You probably want to have some documentation that you made a good faith effort to collect the data, since you are probably required to file an annual AAP.
I would agree that it is likely you are required to have an affirmative action plan and need to collect your applicant data. We are a bank as well and do an annual plan (which is outsourced -- if you want to know whom we use, I would be happy to share -- they do a nice job for us).
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