Okay....we did a C/P loan and here are the details and my subsequent questions are below:
Date of original app for the C/P loan was 4/24/08.
The loan went from construction to perm financing on 12/23/09.
There is no new credit application or new credit report pulled prior to closing on the perm financing.
There was a 2nd flood pulled on 12/16/09.
There is an approval in the file from 5/08 for the loan, but no subsequent approval for the perm financing.
On the original app, the borrower did not wish to disclose race, ethnicity, sex. The lender never obtained GMI info (until now when we went to book the loan and needed it).
For HMDA purposes
1) What is the application date?
2) What is the approval date?
3) What is the best way to document how we collected GMI?