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#186498 - 05/04/04 03:23 PM Govt Monitoring Form Not Obtained
Anonymous
Unregistered

What if a lender fails to obtain a govt monitoring form for a HMDA reportable loan during the application process or even by closing. Is there an issue with going back to the customer after-the-fact to obtain the information? If we cannot "fix" the oversight, do we have to report the information as NA and accept it as a violation? Any help on a solution would be appreciated.

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Lending Compliance
#186499 - 05/04/04 03:44 PM Re: Govt Monitoring Form Not Obtained
Pale Rider Offline
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Pale Rider
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Couldn't the lender or the processor complete the GMI from memory ? It is costly to go back to the customer. The regulators would like to see some additional training so that this type of event doesn't become a pattern or practice.
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#186500 - 05/04/04 03:52 PM Re: Govt Monitoring Form Not Obtained
Anonymous
Unregistered

At our bank, if we fail to gather the monitoring information, we always send out the disclosure and monitoring information form to the customer, and if the customer does not respond, then the LO will complete it based on their past visual observation.

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#186501 - 05/05/04 03:11 PM Re: Govt Monitoring Form Not Obtained
Anonymous
Unregistered

Our LO's have been doing it from memory. We use Gulfpak and the Supplemental GMI form they have doesn't ask for a customer signature so we don't have to have them come back or mail it out for them to sign.

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