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#1812237 - 05/08/13 04:33 PM GMI - Email Application
Multiple Hats Offline
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Joined: Jul 2008
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Application emailed in without GMI. Applicant came in next day to give tax returns. Loan officer made visual observation and filled out GMI on a sheet. This was before a decision was made on the loan. I've heard this is ok to do with an application receive via the mail. Is this ok via an electronic method or is it automatically an exception or even a violation?

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#1812310 - 05/08/13 05:53 PM Re: GMI - Email Application Multiple Hats
Truffle Royale Offline

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The Reg states the GMI may be completed 'during the application process'. Additionally, it states that the information can be captured at time of closing too.

imho, technically the borrower bringing in the tax returns was past the application process part of this so I advise our LOs to leave it blank.

fwiw, when the decision is made has no bearing on application and GMI.

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#1812357 - 05/08/13 06:57 PM Re: GMI - Email Application Multiple Hats
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Posts: 21,277
Originally Posted By: Wear 2 Many Hats
Application emailed in without GMI. Applicant came in next day to give tax returns. Loan officer made visual observation and filled out GMI on a sheet. This was before a decision was made on the loan. I've heard this is ok to do with an application receive via the mail. Is this ok via an electronic method or is it automatically an exception or even a violation?

This is fine within the regulation, you are within the application processing phase, but your bank should have a standard process and not just employees randomly deciding when to report and when not to report. You want consistency in handling if and how this is done.
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