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#2024183 - 06/30/15 07:55 PM GMI COLLECTED ON NON HMDA REPORTABLE LOAN
fnblikdd Offline
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Joined: Apr 2013
Posts: 15
NY
: Confused in NY:
Scenario - application is received for what would typically be a HMDA reportable loan (Refi of a dwelling to be the primary residence of 1 family). GMI is collected. Later down the road in the process, it is determined that this will be a Consolidation / Modification of the existing loan. CEMAs (otherwise known as MECAs) are not HMDA reportable (unless for the purpose of purchase or Home Improvement). Now I have an application for a loan that is not HMDA reportable but we have collected the GMI. Should a notation be made on the application that the GMI was collected in error?
confused

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#2024185 - 06/30/15 07:58 PM Re: GMI COLLECTED ON NON HMDA REPORTABLE LOAN fnblikdd
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Well, it wasn't in error when it was collected. I would note the file that the loan type changed.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
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#2024202 - 06/30/15 08:26 PM Re: GMI COLLECTED ON NON HMDA REPORTABLE LOAN fnblikdd
Princess Romeo Offline

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Posts: 8,272
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From the Commentary of Regulation B:

Official Interpretations of this section.
Section 1002.13—Information for Monitoring Purposes

13(b) Obtaining of information.

Quote:
6. Inadvertent notation. If a creditor inadvertently obtains the monitoring information in a dwelling-related transaction not covered by §1002.13, the creditor may process and retain the application without violating the regulation.
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Regulations are a poor substitute for ethics.
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#2024231 - 06/30/15 10:10 PM Re: GMI COLLECTED ON NON HMDA REPORTABLE LOAN fnblikdd
Princess Romeo Offline

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Where the heart is
For some reason, auditors and examiners have convenient amnesia when they find GMI in a non-reportable dwelling secured loan. Be sure to copy the above item from the Commentary (complete with the regulation section cite) in your notation in the file.
_________________________
CRCM,CAMS
Regulations are a poor substitute for ethics.
Just sayin'

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#2024239 - 06/30/15 11:19 PM Re: GMI COLLECTED ON NON HMDA REPORTABLE LOAN fnblikdd
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,281
This wasn't even inadvertent. It changed to a modification.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2024277 - 07/01/15 01:05 PM Re: GMI COLLECTED ON NON HMDA REPORTABLE LOAN fnblikdd
fnblikdd Offline
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Joined: Apr 2013
Posts: 15
NY
Kathleen is correct, it wasn't inadvertent. But your feedback has cleared the fog from my brain. Thank you all for your responses and feedback.

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