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#1705388 - 05/31/12 08:26 PM Collecting Government Monitoring Information
Arizona Offline
100 Club
Joined: Nov 2009
Posts: 106
Our marketing department would like to redesign our internal loan application to incorporate government monitoring information. We do not use FNMA 1003 for residential loan applications, we use our internal applications for every type of loan request. A separate form is used to collect gov monitoring info.
If the information is collected on the new application form and the loan request was not for a dwelling would there be any repercussions?

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#1705432 - 05/31/12 09:01 PM Re: Collecting Government Monitoring Information Arizona
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,470
Midwest
Do you have different applications for real estate secured and non-real estate secured?

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#1705441 - 05/31/12 09:06 PM Re: Collecting Government Monitoring Information Arizona
Arizona Offline
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Joined: Nov 2009
Posts: 106
No same application used for every type of request.

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#1705676 - 06/01/12 03:56 PM Re: Collecting Government Monitoring Information Arizona
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 8,767
OK
Originally Posted By: Arizona
If the information is collected on the new application form and the loan request was not for a dwelling would there be any repercussions?


You definitely don't want to be routinely gathering GMI on loans not subject to the GMI requirements.
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#1705681 - 06/01/12 04:08 PM Re: Collecting Government Monitoring Information Arizona
ahkcompliance Offline
Diamond Poster
Joined: Sep 2008
Posts: 2,470
Midwest
I agree you don't want to continually collect GMI when it is not needed. I would think examiners would frown upon this. I think your best option would be to either continue what you do now by using the seperate sheet or develop other applciations one for RE secured and one for Non RE secured.

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#1706087 - 06/04/12 01:27 PM Re: Collecting Government Monitoring Information Arizona
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
Examiners will cite a Reg B violation if you collect GMI for any loan other than a loan to purchase of refinance a primary dwelling or that is covered by HMDA.
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#1709216 - 06/12/12 01:22 PM Re: Collecting Government Monitoring Information Arizona
#Just Jay Offline
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#Just Jay
Joined: Oct 2006
Posts: 14,390
Cheeseheadland
Exactly... one app where it is collected incorrectly will most likely find it onto your exam as a finding.

Ensure you have strong training and controls in place going forward.
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