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#1634265 - 12/01/11 06:03 PM GMI or Not?
dollars & sense Offline
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Joined: Oct 2006
Posts: 338
Our bank is not located in an MSA so we don't need to report HMDA data.

That being said our bank has selected to compile a LAR to meet the OCC record keeping requirements insead of their Home Loan Activity Format. This helps us disect information for fair lending analysis.

For a home improvement loan if you are a HMDA reporter you collect GMI. However we are not a HMDA reporter. Should we collect GMI on this type of loan since we comple but don't sumbit a LAR or is this a violation?

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#1634296 - 12/01/11 06:34 PM Re: GMI or Not? dollars & sense
AFaquir Offline
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AFaquir
Joined: Jan 2011
Posts: 763
Top of the world... and never ...
I would honestly contact your regulator to determine the most appropriate course of action with this... since collecting when you shouldn't is a violation... even if you are collecting for internal reasons.

Cheers!
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