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#1525080 - 03/22/11 04:01 PM GMI on co-borrowers
Southern gal Offline
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Posts: 504
TN
Does GMI have to be collected on a co-borrower? Is this addressed in the reg?

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Lending Compliance
#1525084 - 03/22/11 04:06 PM Re: GMI on co-borrowers Southern gal
raitchjay Online
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Joined: Oct 2009
Posts: 9,105
OK
Yes, co-borrower GMI should be collected. From the GIR:

Applicant Information
Ethnicity, race, and sex of the
applicant. Report ethnicity, race, and
sex both for loans that you originate
and for loan applications that do not
result in an origination. At your option,
you may report those data for loans
that you purchase. Report the data
for the applicant and for the CO-APPLICANT,
if there is one. If there is no
co-applicant, use the numerical code
for “no co-applicant” in the “coapplicant”
column. For more information,
see Appendix A, I.D., Appendixb)

(From Reg. B, 202.13(2)(b), if you were referring to this from a Reg. B perspective.)

Obtaining information. Questions regarding ethnicity, race, sex, marital status, and age may be listed, at the creditor's option, on the application form or on a separate form that refers to the application. The applicant(s) shall be asked but not required to supply the requested information. If the applicant(s) chooses not to provide the information or any part of it, that fact shall be noted on the form. The creditor shall then also note on the form, to the extent possible, the ethnicity, race, and sex of the applicant(s) on the basis of visual observation or surname.

B, and the staff comments to Regulation
C § 203.4(a)(10).

Last edited by raitchjay; 03/22/11 04:10 PM.
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#1525115 - 03/22/11 04:23 PM Re: GMI on co-borrowers raitchjay
Southern gal Offline
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Joined: Mar 2008
Posts: 504
TN
Thanks, sorry I failed to mention we are not a HMDA reporting FI, but we still need GMI on co-borrowers?

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#1525222 - 03/22/11 05:51 PM Re: GMI on co-borrowers Southern gal
raitchjay Online
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Joined: Oct 2009
Posts: 9,105
OK
Yes.
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#1525225 - 03/22/11 05:52 PM Re: GMI on co-borrowers Southern gal
manimal Offline
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manimal
Joined: Feb 2008
Posts: 2,207
Deleted
I would think since the Reg. B rule uses the term "applicant(s)", this implies both the borrower and co-borrower.
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#1525237 - 03/22/11 05:57 PM Re: GMI on co-borrowers Southern gal
Dan Persfull Offline
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Dan Persfull
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Posts: 47,532
Bloomington, IN
You will need to follow the rules under Reg. B 202.13 and its Commentaries.
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#1525355 - 03/22/11 07:20 PM Re: GMI on co-borrowers Dan Persfull
Southern gal Offline
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Joined: Mar 2008
Posts: 504
TN
Thanks Dan, Now the loan officer is telling me the GMI was not obtained because co-borrower was not going to be living in the house. Shouldn't he document this on the app as to why GMI was not obtained?

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#1525370 - 03/22/11 07:28 PM Re: GMI on co-borrowers Southern gal
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
The loan officer is correct. If the dwelling will not be the co-borrower's primary dwelling then GMI would not be collected on them. Under Reg B it's only required for the applicants that the dwelling will be their primary dwelling.

You are also correct this fact should be documented; otherwise how will you, an auditor or examiner know the property is not, or was not intended to become the co-borrower's primary dwelling.
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#1525720 - 03/23/11 02:30 PM Re: GMI on co-borrowers Dan Persfull
Southern gal Offline
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Joined: Mar 2008
Posts: 504
TN
Thanks again!

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