Was tired of dealing with HMDA reportable multi-family loans to a business entity AND an individual co-borrower without the lender obtaining the required government monitoring information on the co-borrower, that I had to do something. To resolve the issue I suggested putting the GMI on a separate sheet to be used for this type of loan. Our practice -- supposed to be anyway, complete an URLA!

Now the loan admin folks want my head! They say my GMI form will be used on all HMDA reportable commercial deals. Is that so wrong? When is a written application required, I mean other than when you have a natural person & personal residence.

This brings me to the commercial loan deals that include the business owner's personal residence & in 2004 will be a HMDA refi. If I'm reading Reg B correctly I need a written application & GMI.

I should be at the couch I'm so confused -- I guess I'm asking when in the situations I have described is a written application needed & when is GMI info sufficient! PS, @this point reading 202.13 just adds to my confusion.

The only time a written application is required by the regulation is when the loan is for the purchase or refinance of the borrower’s principal dwelling and the loan will be secured by that dwelling.

For HMDA, a refi is the replacement of a loan secured by a dwelling with a new loan secured by a dwelling. And as previous discussions have revealed there will be a lot of loans reported that have nothing to do with a HMDA purpose because of this definition.

For Reg B, and this is my interpretation, a refi is for the purpose of reducing the term or interest rate only. Any new money takes it into the purpose of the new money. Therefore if I took out the equity of my home to purchase a boat, HI or whatever and consolidate all that with what I owe on the first lien, I am taking out an equity loan secured by a first lien. The purpose of my loan was not to refinance my home. Again this is my interpretation.