We have recently revised our procedures to require that ALL HMDA transactions must have a written application. I realize that per reg. B, this is a requirement for primary resident purchases, but since we use the app as a source document for several LAR entries, we have requested a written app for all HMDA loans.
Would this be a practicle requirement to ask for on commercial loans (ie, the purchase of an apartment complex). I want to say no, but fear making an exception would circumvent the need for a written app on some HMDA transactions that actually needed one.
Can anyone advise?