My question is that our compliance department is asking operations to gather GMI on all unsecured consumer loans that are currently on our books. The purpose is to run comparisons for fair lending. I have researched this and find that it is not allowable under Reg B, however the argument is that these are already our loans and we are not asking the borrower for it up front to make a lending decision. I would appreciate your opinion.
We have a loan application that was taken face to face. The LO marked the GMI sex box as female when the borrower was male. Obvious mistake. The loan closed without being corrected. We have had contradicting information from auditors and regulators that say that we report exactly what was put on the application and that we should report the correct sex as we know it was an error.... which way do we go here?
Our loan software provider has recently deleted the Government Monitoring Form from the list of required documents on loans subject to HMDA. Is this completed form no longer required on HMDA loans?.
Is the date on the Information for Government Monitoring Purposes supposed to be the same date as the credit application?
Would a trust be considered a legal entity or natural person when it comes to Truth in Lending, RESPA, and HMDA disclosures?
HMDA - GMI: two applicants but only one signed the note. What GMI do we report on the LAR?
When do you NOT need to collect government monitoring information?
On a Broker application, is the investor allowed to correct the Government Monitoring Information if what is marked is not consistent with the picture ID in the file?
I have a question regarding the government monitoring information requirements under Section 202.13 of Reg B</a>. We are not a HMDA reporting bank. If we were to do a home equity loan for a customer and then that same customer requested additional money on that home equity (or a refinance), would you then at that point be required to collect government monitoring information?
Under the current Truth in Lending payment schedule guidelines, payments on FHA loans with MIP are shown as â€¦for example 111 payments $1782.57 to 1726.23 249 payments $1489.01. I believe the correct input in APRWin would be: 111 $1726.23 And then 249 $1489.01. Why is the input valid using the lower payment amount ($1726.23) and not the higher ($1489.01)?