Does anyone else have this problem??
We are a small bank and are not located in an MSA therefore we are subject to HMDA GMI reporting. Per Reg B we are required to collect GMI on real estate loans EXCEPT construction loans. However, in looking at the Holden Act, it looks like we are supposed to be collecting GMI but not reporting it to anyone. Has anyone found a way to comply with this contradiction of the law? (Holden Act, CA Health & Safety Code 35815-35816)
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