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#1844524 - 08/21/13 05:18 PM HMDA - GMI? LLC to be formed
KMayotte Offline
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Joined: Aug 2013
Posts: 3
Worcester, MA
Hoping someone can clarify for me ... here is the situation:

We had a customer interested in purchasing a multi-family dwelling. The customer indicated that he would form an LLC to hold title to the property - our Borrower would have been the newly formed LLC and the guarantor would have been the customer. Since the loan didnít close Ė it was declined Ė is GMI required for the customer (who would have been the guarantor) or the LLC to be formed? We donít have a formal application on file, just several e-mails between the lender and the customer where it was specifically noted that the new LLC would be the borrower. If the loan had booked, we would have completed the GMI based on the LLC. The letter of adverse action was mailed to the customer (guarantor).

Thank you,
Kathy

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#1844528 - 08/21/13 05:23 PM Re: HMDA - GMI? LLC to be formed KMayotte
TMatt87 Offline
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TMatt87
Joined: May 2011
Posts: 1,932
Idaho
Was this an actual application or just an inquiry?
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#1844534 - 08/21/13 05:40 PM Re: HMDA - GMI? LLC to be formed KMayotte
KMayotte Offline
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Joined: Aug 2013
Posts: 3
Worcester, MA
We didn't have a formal application - it came through the commercial lending department. It wasn't an inquiry; a notice of adverse action was sent.

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#1844594 - 08/21/13 07:00 PM Re: HMDA - GMI? LLC to be formed KMayotte
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,839
Bloomington, IN
IMHO until the LLC was formed the individual was your applicant and you should have collected information based on that.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1844599 - 08/21/13 07:03 PM Re: HMDA - GMI? LLC to be formed KMayotte
KMayotte Offline
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Joined: Aug 2013
Posts: 3
Worcester, MA
Thank you, Dan. That's what we were leaning toward.

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