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#1719446 - 07/12/12 04:59 PM GMI Collection
nikicole03 Offline
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Joined: May 2012
Posts: 6
I'm seeing different opinions on when to collect/complete GMI information for loans taken by Phone, Internet or Mail.

Per the guide: Applicant data—application completed in person - When an applicant meets in person with a lender
to complete an application that was begun by mail, Internet, or telephone, the institution must request the monitoring information. If the meeting occurs after the application process is complete, for example, at closing, the institution is not required to obtain monitoring information.

Some people are saying that any face-to-face meeting with the applicant after they submit their telephone/internet/mail application requires us to complete the GMI based on visual observation. Is this just misinterpretation of the above?

That brings in question then, when do you consider the application to be "begun" vs. "complete"? Is it considered an incomplete application until closing? If it's not complete, but then you meet face-to-face later, are you switching the application taken to Face-to-Face?

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#1719493 - 07/12/12 06:03 PM Re: GMI Collection nikicole03
raitchjay Online
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Joined: Oct 2009
Posts: 8,721
OK
HMDA's definition of an application is pretty generic and basically points you back to the bank's internal policies and procedures. I would say that when you have the information (from the borrower) that your bank normally requires to make a decision on a request, your application process is complete. So, if an application is begun on the phone, internet, or mail, but the bank doesn't have everything they'd normally need to make a decision and then a face to face meeting occurs to finish that up, you'd need to collect GMI. If you get all the information that you need to make a decision and then meet the applicants face to face, GMI wouldn't be required. Just my interpretation.
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