Inadvertent Monitoring Information Collection
by Mary Beth Guard, BOL Guru
One provision in the recent Regulation B amendments which will make many creditors breathe a sigh of relief is a portion of the revised commentary which states that if a creditor inadvertently obtains the monitoring information in a dwelling-related transaction not covered by § 202.13, the creditor may process and retain the application without violating the regulation. This is important because a misunderstanding about the nature of the loan request, made at the time the application form is delivered to the applicant, can quite easily result in the wrong form being given.
You should still train your frontline personnel to ask the right questions and strive to give out the proper application form to each applicant, but it's comforting to know that in the event of an inadvertent error that results in monitoring information being requested where it should not be, no violation will result.
The original version appeared in the March 2003 edition of the Oklahoma Bankers Association Compliance Informer.
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