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#1717872 - 07/06/12 07:45 PM Request Government Monitoring Information?
rachelchri Offline
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Joined: Aug 2010
Posts: 165
We are a National Bank not subject to Reg C (HMDA). When we receive an application to refinance home for the purpose of debt consolidation, we do not have to collect the GMI, correct?

Also, would it be considered a violation if we do?

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#1717875 - 07/06/12 07:47 PM Re: Request Government Monitoring Information? rachelchri
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
Under Reg B, you collect if it's for the purchase, or refinance of purchase money only. So, if you HI includes paying off purchase money - yes. Otherwise, no.


ETA: Missed the last question. Yes.
Last edited by RR Joker; 07/06/12 07:52 PM.
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#1717880 - 07/06/12 07:50 PM Re: Request Government Monitoring Information? rachelchri
Gatorgirl Offline
Member
Joined: Jun 2007
Posts: 55
Florida
I am thinking it is not a violation if you are collecting as allowed under Reg B. even though you currently do not do HMDA reporting. I am assuming you are in a rural area?

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#1717891 - 07/06/12 08:04 PM Re: Request Government Monitoring Information? rachelchri
rachelchri Offline
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Joined: Aug 2010
Posts: 165
Yes, we are in a rural area. So, just to be clear:

Purchase Money Transaction (Home secured ) - Yes
Refinance of Home purchase (no new cash) - yes
Refinance to payoff Credit Cards - Big No No.
Refinance for Home Improvements - Big No No.

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#1717892 - 07/06/12 08:06 PM Re: Request Government Monitoring Information? rachelchri
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,281
That is correct! Only purchase and refi of purchase.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1717894 - 07/06/12 08:07 PM Re: Request Government Monitoring Information? rachelchri
rachelchri Offline
100 Club
Joined: Aug 2010
Posts: 165
Thanks Guys!!

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#1717906 - 07/06/12 08:16 PM Re: Request Government Monitoring Information? rachelchri
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
On number 2...it could be cash or no cash out (which would also apply to paying off bills/making improvements). They key is...are you paying off original purchase money with the new loan.
Last edited by RR Joker; 07/06/12 08:17 PM.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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