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#1605476 - 09/19/11 05:14 PM Holder Act vs. Reg B & HMDA GMI collection
AKA nan Offline
100 Club
Joined: Mar 2008
Posts: 156
California
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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#1605627 - 09/19/11 07:59 PM Re: Holder Act vs. Reg B & HMDA GMI collection AKA nan
Al Miller Offline
Diamond Poster
Al Miller
Joined: Oct 2000
Posts: 2,416
Pleasanton CA USA
I believe that compliance with HMDA is presumed compliance with H&S ยงยง 35815 & 35816.

Al
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Al Miller, CRCM
Opinions expressed are my own and not necessarily shared by my employer.

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