On original application, borrower did not furnish information. App was provided by mail.
At closing, application was typed and updated with current information and GMI information was checked. Which do we use when reporting HMDA?

As long as the GMI was collected by the loan officer prior to closing I would report it. If that is the case I would reach out the loan officer for documentation:

When was GMI collected?
Did the applicants provide or was it done on the basis of visual observation?

We used to have a problem with GMI "magically" appearing. We provided training to the LO's that documentation must be provided and that any differences between the original application and the final application must be explained.

GMI cannot be collected when docs are signed, so hopefully that was not the case.

Good luck!

GMI is allowed to updated at closing, including by visual observation. Find out the specifics. Was the customer asked to complete the incomplete section or did a bank employee complete?

Either way it is allowable but should not be done randomly. It should be an acknowledged process of the bank.

How does your financial institution normally obtain GMI that a customer did not complete and did not mark "does not wish to provide"?

Word of caution: Be consistent on how you handle these situations.
Either you collect the information at closing on ALL loans that are missing GMI or don't.
Reg C is based on the original application, not the final one signed at the closing table.
While the Reg does allow for collect at closing, it does not mandate it.
Here we've determined that collecting at closing would skew our reporting so we don't do it.
Ex: Two applications come in by mail with nothing marked in the GMI section. Only one loan actually closes. The other is denied without anyone actually having any contact with the borrower to ask or collect the GMI. Both of these loans will go on my LAR as 'information not provided in mail application'.

What do you do if you have a HMDA reportable loan to an individual, the loan officer did not collect GMI on the application at application, and the loan closes with the information ever having been completed?

Tell the loan officer they need to call and get it (and tell them next time, do it right the first time).

Can I assume that the loan officer can complete a GMI form on the basis of observation - assuming they were at close with the borrowers?

I don't know about assuming that ( ), but if they did see the borrowers at application, i'd get them to fill out the GMI and note that it was based on visual observation. Your only other option is to not report GMI and i don't like that option when the LO simply goofed and didn't get it.

Agreed! Thanks, raitchjay. I have been requesting the LO to complete the GMI after the fact when I come across an instance.