Hello,

So i was wondering what you guys do at your banks, at our bank we have to complete a final application that is typed for our secondary market loans, on the HMDA collection, do you fill out the information from the original application, leave it blank, or fill it our like the customers are sitting there at closing?

thanks!

Final applications CONFIRM what was on the original application so it should match except for minor things like actual account balances vs guesstimates that were on original.

As to GMI, the Reg allows you to collect at the closing.
If you search this forum, you'll find two schools of thought on that.
One will collect it.
The other, of which I am one, believes that collecting at closing skews your data.
Consider two internet applications that both had no GMI info.
One closes and you collect at closing.
The other is denied so you never see the borrower to collect.
I would report both the same with no info, thereby confirming what was on the original.

Truffle: I don't believe HMDA or Reg B allow you to collect GMI at closing. It needs to be collected at the time of application. Refer to §1002.13(a)(1) and (b). §1003.4(a) indicates information applies to applications, not loans.

David, with no supporting documentation I could find on a search here from home and not to point fingers, but I'm sure it was Dan who landed on the other side of this fence regarding collecting it at closing. Maybe he'll chime in tomorrow with the proper reference. I'll try to look for it at work tomorrow too.