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#1415795 - 07/16/10 02:16 AM Government MonitoringOur
Anonymous
Unregistered

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.

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#1415972 - 07/16/10 03:39 PM Re: Government MonitoringOur Anonymous
Cowboys Fan Offline
Power Poster
Joined: Dec 2002
Posts: 4,598
SC
Purchase or refi principal residence / secured by principal residence. Construction only loans are exempt.
_________________________

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#1420294 - 07/27/10 04:47 PM Re: Government MonitoringOur Cowboys Fan
Anonymous
Unregistered

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?

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#1420343 - 07/27/10 05:32 PM Re: Government MonitoringOur Anonymous
Al Miller Offline
Diamond Poster
Al Miller
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
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
_________________________
Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.

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#1420368 - 07/27/10 05:58 PM Re: Government MonitoringOur Al Miller
80's Lady Offline
Gold Star
Joined: Apr 2007
Posts: 295
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.
_________________________
I use to think I was a smart cookie before I started working in Compliance. Now, I have mastered the art of the blank stare!

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