We created a "GMI" form for the commercial loan officers. It was the basic information that is similar to Appendix B in HMDA - GIR.
We added a line on the bottom with "application date" and the LO's signature. Since they are supposed to get information at application, this was used as proof to document the date. Regulators have had no issue with it.
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Integrity. With it, nothing else matters. Without it, nothing else matters.