So we have a mailed in application that is a purchase of a primary residence. The applicants did not provide the GMI nor did they mark that they do not wish to furnish this information. It has been our policy for HMDA that we do not collect the GMI at closing if it was not provided to us during the application by mail, phone or internet.

So the question is do we collect the Reg. B GMI at closing? Or follow our HMDA process and say it was not provided by applicant?

In the commentary of Regulation B it says

"A creditor that accepts an application by mail need not make a special request for the monitoring information if the applicant has failed to provide it on the application form returned to the creditor."

So I am thinking asking for it again at closing would be a special request? Any help would be appreciated!

Do you close your loans in house or have an agent do the closing?

You know me, I swear by KISS. I'd follow my HMDA policy and go with information not provided by mail, internet, or telephone. Reg B says you can.

It was not provided, your policy is you go with that, I would stick with "not provided".