When reporting a 'refi' of a commercial loan where the collerateral is a dwelling how are banks collecting GMI if a new application is not obtained? Can we do surname observation? or complete because we know the race and sex? or must we give the 'natural person' an opportunity to disclosure or not disclosure gov't monitoring info?

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or must we give the 'natural person' an opportunity to disclosure or not disclosure gov't monitoring info?

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This is what should be done.

The tools section has a GMI collection form we use for loans not taken on a 1003 or where an application is not used.

GMI Collection Form

All the loan officers have that form now - getting them to use it will be another thing.....I just thought we could get away with surname observation or because we know it, since they never come into the bank for this 'refi'...but thank you.....