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#2003257 - 03/23/15 02:25 PM Collected GMI - Black out or not?
Melissa S Offline
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According to an article I found from 11/23/11 on Trinovus titled HMDA: The Collection of Government Monitoring Information, if GMI is collected in error, it should be blacked out and the following added: "This information was taken inadvertently and deleted from the file on", date it, and initial it.

I have an application that was received as (Corp Name) +/or (Individual Name) and the GMI was completed by the individual.

The loan was closed in the corporate name, and now I have GMI that I should not have; except for the fact the individual had indicated on the app that he may act as borrower.

Do I need to black out the GMI information?
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#2003280 - 03/23/15 03:12 PM Re: Collected GMI - Black out or not? Melissa S
swiggles Offline
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If the individual initially applied as joint borrower with the Corp, gathering GMI was permitted. If it closed just in the Corp name, I don't think it need to be blacked out, because at application, you were required to ask for it....you just don't report it. But since the closed only in the Corp name, no violation as I see it. The GMI on the individual was not inadvertantly gathered. It was gathered on purpose.

The deeper question is....why was the individual dropped from the ap? Did he not qualify credit wise? If so, you owe him an AAN.
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#2003284 - 03/23/15 03:17 PM Re: Collected GMI - Black out or not? Melissa S
Melissa S Offline
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Swiggles - the borrower was not dropped due to anything on the financial institution end. At the time of the app, the individual did not know whether he wanted to borrow as the corporation or as an individual. So he completed the app as "+/or". The individual determined that the funds would be loaned to the corporate borrower on a standalone basis.

Thank you for your answer!
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#2003295 - 03/23/15 03:36 PM Re: Collected GMI - Black out or not? Melissa S
Skittles Offline
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I also wouldn't alter an application. If it was collected and shouldn't have been I would have the loan officer indicate 'Completed by customer in error'. And, of course, retrain if necessary.
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#2003310 - 03/23/15 03:57 PM Re: Collected GMI - Black out or not? Melissa S
Melissa S Offline
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Thanks, Skittles!
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#2003330 - 03/23/15 04:35 PM Re: Collected GMI - Black out or not? Melissa S
Kathleen O. Blanchard Offline

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I imagine the idea behind "blacking out" is so you do not have GMI that you are not allowed to have, that could potentially be used to discriminate. By "blacking out" it can't be viewed.

I would not do that. I would notate that it was obtained in error. By the time this is noticed, the application has likely been processed and blacking it out serves no purpose.

In your case it does not apply because at the time the GMI was obtained, it was required.
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#2003335 - 03/23/15 04:43 PM Re: Collected GMI - Black out or not? Kathleen O. Blanchard
kw004h Offline
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Originally Posted By: Kathleen B
I imagine the idea behind "blacking out" is so you do not have GMI that you are not allowed to have, that could potentially be used to discriminate. By "blacking out" it can't be viewed.



Perhaps another reason to black it out is as a reminder so that the "wrong" GMI information doesn't make its way into the HMDA LAR?

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#2003336 - 03/23/15 04:44 PM Re: Collected GMI - Black out or not? Melissa S
Kathleen O. Blanchard Offline

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But you could also just draw an X. Blacking out seems extreme.
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#2003345 - 03/23/15 05:14 PM Re: Collected GMI - Black out or not? Melissa S
David Dickinson Offline
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I've never heard of anyone blackening out the GMI after it was collected. I don't believe this is supported by any regulatory guidance either. You collected it (and it won't be the last time). Note the error and move on.
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