Thread Options
|
#2102556 - 10/11/16 06:33 PM
GMI on Commercial loans
|
Platinum Poster
Joined: Sep 2003
Posts: 729
|
How are other's collecting the GMI on Commercial loans? Our commercial applications do not have the GMI portion like a 1003 does, so how are other bank's collecting this information on a commercial application? We have very few commercial properties that are subject to HMDA, but curious how other's do this for their commercial applications?
|
Return to Top
|
|
|
|
#2102562 - 10/11/16 06:46 PM
Re: GMI on Commercial loans
Snowgirl
|
Power Poster
Joined: Oct 2009
Posts: 9,105
OK
|
We use a stand-alone supplemental GMI form.
_________________________
I'm fixin' to fix that.
|
Return to Top
|
|
|
|
#2102565 - 10/11/16 06:52 PM
Re: GMI on Commercial loans
Snowgirl
|
Platinum Poster
Joined: Sep 2003
Posts: 729
|
Thanks Raitchjay. Just needing a little clarification. When an application comes in for a commercial property, at what point do you give this supplemental form? That is the hard part for us, as a lot of times it is not clear if it is HMDA reportable at that point until after the fact when it is reviewed and determined that it will in fact be HMDA reportable, so at what point and how do you give that supplemental form?
|
Return to Top
|
|
|
|
#2102595 - 10/11/16 07:54 PM
Re: GMI on Commercial loans
Snowgirl
|
Gold Star
Joined: Jun 2002
Posts: 255
Southeast Michigan
|
We also use a short form. The key is training for the lenders. The only thing commercial lenders need to know about HMDA is 1) to recognize a HMDA-reportable loan, 2) when GMI is required, and 3) how to complete the GMI form properly. It is essential that they know it must be done at application time, however they define that. Remind them that, if the customer backs out or the credit is turned down, the GMI is still needed and is pretty difficult to get, at that point.
I can't wait for the new HMDA rule!
_________________________
My comments and opinions are my own, not my employer's.
|
Return to Top
|
|
|
|
#2102610 - 10/11/16 08:26 PM
Re: GMI on Commercial loans
Snowgirl
|
10K Club
Joined: Sep 2002
Posts: 13,965
TN
|
We do what David suggested.
_________________________
My Opinions Only
|
Return to Top
|
|
|
|
#2102622 - 10/11/16 10:42 PM
Re: GMI on Commercial loans
Snowgirl
|
Platinum Poster
Joined: Sep 2003
Posts: 729
|
And what "disclaimer" is required? Are you meaning the information that is on the 1003
"The following information is requested by the Federal Government for certain types of loans related to a dwelling in order to monitor the lender's compliance with equal credit opportunity, fair housing and home mortgage disclosure laws. You are not required to furnish this information, but are encouraged to do so. The law provides that a lender may not discriminate either on the basis of this information, or on whether you choose to furnish it. If you furnish the information, please provide both ethnicity and race. For race, you may check more than one designation. If you do not furnish ethnicity, race, or sex, under Federal regulations, this lender is required to note the information on the basis of visual observation and surname if you have made this application in person. If you do not wish to furnish the information, please check the box below. (Lender must review the above material to assure that the disclosures satisfy all requirements to which the lender is subject under applicable state law for the particular type of loan applied for.) BORROWER I do not wish to furnish this information"
|
Return to Top
|
|
|
|
#2102623 - 10/11/16 10:43 PM
Re: GMI on Commercial loans
Snowgirl
|
Platinum Poster
Joined: Sep 2003
Posts: 729
|
Also, what happens if we do not give this supplemental form to the borrowers and instead the loan officer completes it every time for the borrowers?
|
Return to Top
|
|
|
|
#2102625 - 10/11/16 11:00 PM
Re: GMI on Commercial loans
Snowgirl
|
Diamond Poster
Joined: May 2011
Posts: 1,987
Idaho
|
Yes, that is the disclaimer. You are required to give the applicants the opportunity to complete the government monitoring information. If the borrower's do not wish to provide the information, and the application process was in person, the loan officer then will fill out the GMI based on visual observation or surname. It is a violation of HMDA to not give the applicants the opportunity to complete the GMI. See Appendix B to HMDA for more info.
Last edited by TMatt87; 10/11/16 11:03 PM.
_________________________
All opinions are my own, not my employer's
|
Return to Top
|
|
|
|
#2102703 - 10/12/16 04:54 PM
Re: GMI on Commercial loans
Snowgirl
|
Platinum Poster
Joined: Sep 2003
Posts: 729
|
|
Return to Top
|
|
|
|
#2260578 - 10/01/21 04:19 PM
Re: GMI on Commercial loans
Snowgirl
|
Power Poster
Joined: Nov 2003
Posts: 3,726
|
What if your borrower is an entity? Do you collect GMI on the principals or do you put N/A? Where can I find information on this in the rule, HMDA Guide to Getting it Right or elsewhere?
Thanks in advance.
_________________________
It's not that I take life for granted. It's only that the good won't make it. Innocence dies, while Villany Thrives.
|
Return to Top
|
|
|
|
#2260583 - 10/01/21 04:51 PM
Re: GMI on Commercial loans
Snowgirl
|
Power Poster
Joined: Oct 2009
Posts: 9,105
OK
|
7. You must report that the requirement to report the applicant's or co-applicant's ethnicity, race, and sex is not applicable when the applicant or co-applicant is not a natural person (for example, a corporation, partnership, or trust). For example, for a transaction involving a trust, you must report that the requirement to report the applicant's ethnicity, race, and sex is not applicable if the trust is the applicant. On the other hand, if the applicant is a natural person, and is the beneficiary of a trust, you must report the applicant's ethnicity, race, and sex.
_________________________
I'm fixin' to fix that.
|
Return to Top
|
|
|
|
#2260584 - 10/01/21 04:51 PM
Re: GMI on Commercial loans
Snowgirl
|
Power Poster
Joined: Oct 2009
Posts: 9,105
OK
|
That's from Appendix B.
_________________________
I'm fixin' to fix that.
|
Return to Top
|
|
|
|
|
|