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#1892787 - 01/31/14 10:14 PM Reg B GMI collection on Home Improvment
Combustible Offline
Diamond Poster
Joined: Dec 2008
Posts: 1,268
I think we've been doing this wrong. We are auditors for a holding company with both Reg B & Reg C affiliate banks.It was always our understanding we should collect GMI on Reg B bank's home improvement loans, but recently I've read in a couple of different articles Reg B Banks are not allowed to collect GMI on Home Improvement loans. Should I call a staff meeting?

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Lending Compliance
#1892792 - 01/31/14 10:18 PM Re: Reg B GMI collection on Home Improvment Combustible
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,351
You would only collect GMI on a home improvement loan if you're a HMDA reporter. Reg B only mandates collection for the purchase or refinance of a principal residence. Reg C is a "reporting" Reg which expands the GMI collection requirements to include purchase or improvement of ANY dwelling if secured by ANY dwelling and the refinance of a dwelling secured loan if the new loan is secured by a dwelling.
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#1892796 - 01/31/14 10:34 PM Re: Reg B GMI collection on Home Improvment Combustible
Combustible Offline
Diamond Poster
Joined: Dec 2008
Posts: 1,268
Ok, I just called a meeting.

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#1892927 - 02/03/14 03:47 PM Re: Reg B GMI collection on Home Improvment Combustible
Ishmael Offline
100 Club
Joined: Feb 2011
Posts: 232
Pequod
There's an on-point article in the most recent Consumer Compliance Outlook. Good luck!

http://www.philadelphiafed.org/bank-reso...r/cco_q4_13.pdf

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