Our bank is NOT a HMDA bank. Can someone tell us in simple terms when we are required to have GMI? We seem to have gone in circles over this and everyone has a different opinion.

Purchase or refi principal residence / secured by principal residence. Construction only loans are exempt.

Our loan application request this information (stating is for monitoring purposes) and we use the application for all real estate loans (regardless of purpose). By doing so, are we out of compliance if the customer completes the section but really didn't need to?

It is not a question of "really needing to".

Requesting the information when not required is a violation of law and could trigger a referral to the Department of Justice.

Al

We had a similar problem until we created a red stamp with an arrow that says: Complete this section only if this loan is for the purchase or refinance of your primary residence.

This made a huge difference and made the inadvertent collection very rare.