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#2140394 - 08/01/17 07:43 PM
GMI on a different application
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Lender had borrowers fill out an application for a retail loan and a commercial loan at the same time. Both loans are reportable. Is it ok to refer to a different application for the GMI as they will have their own files. Or would it be prudent to keep a copy of the application in the commercial file as well?
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#2140402 - 08/01/17 08:51 PM
Re: GMI on a different application
Bec
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GMI attaches only to the application for which it was gathered. You can't use it for an application for another loan. JMO
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#2140522 - 08/02/17 07:06 PM
Re: GMI on a different application
Bec
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Thanks for the opinions. It was one application that was used for two loans that occurred concurrently. For what its worth, the approach that you suggested, Truffle, was the one I was thinking we could probably perform and it would be a reasonable solution. I think for the best scenario they should have filled out a GMI form for the reportable commercial loan and then we didn't have to worry about it. Would that have been your approach Swiggles?
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#2140527 - 08/02/17 07:12 PM
Re: GMI on a different application
Bec
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Two loans - two applications - two GMI forms.
Amazingly, at a former bank, the compliance officer allowed lenders to use ANY existing GMI form for a subsequent loan.,......never got caught.
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#2140587 - 08/03/17 02:09 PM
Re: GMI on a different application
Bec
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I see your point, Truffle, and agree, but give and inch and they will take a mile. It's easier to just require a separate GMI form for every loan. I think it would be a rare occasion that the scenario posted here would ever occur.
With respect to simultaneous first and second, yes we would use the same application (including GMI) for both loans.
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#2140877 - 08/04/17 06:09 PM
Re: GMI on a different application
Bec
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We take verbal applications all the time, but we reduce the application to writing on an application form for the file....complete with answers to GMI questions, with "telephone interview" marked. But each application has it's own documentary proof. So it's your opinion that we could simply, upon the first HMDA reportable application, obtain GMI and then just keep relying on that same GMI for subsequent loans? I've never heard of this approach except from the former bank, I mentioned above.
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#2140880 - 08/04/17 06:14 PM
Re: GMI on a different application
Bec
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I had to laugh at your comment about taking the GMI from a different application from a previous loan originated years prior. We've had offenders of that. Even with extensive and continual training on how to collect GMI, they still try to pull stuff like that.
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#2140881 - 08/04/17 06:15 PM
Re: GMI on a different application
Bec
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I don't think the intention of the above answers was to carry it forward into infinity. I believe Reg B is okay with once collected [did not verify it, but I know the rules are different], you're done, but not for HMDA.
If, for instance, you have a request for a construction loan to be paid from a perm loan at the same bank...you have one application serving two loans, but requested at the same time. You don't need GMI for the construction, but you do for the perm. If you use the one application for both 'pieces', it's okay that you collected GMI even when it wasn't required. Same scenario.
However, if 5 years later they come in to refinance their mortgage, you would collect it again...New application, new GMI.
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#2140885 - 08/04/17 06:24 PM
Re: GMI on a different application
RR Joker
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Okay....well....I'm confused. The original poster insinuated that the two loan requests were not related except that both were HMDA reportable. Both loans are reportable. Is it ok to refer to a different application for the GMI as they will have their own files.
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#2140888 - 08/04/17 06:40 PM
Re: GMI on a different application
Bec
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But they were requested at the same time .
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#2140895 - 08/04/17 06:59 PM
Re: GMI on a different application
Bec
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Really though, the issue is moot for me because I would never allow it. Quite honestly, I don't think we have ever had that scenario.
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#2140984 - 08/07/17 02:18 PM
Re: GMI on a different application
Bec
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I made the point earlier, but if I were to open the door for this, I would be opening Pandora's box and would likely end up with some violations when lenders try to take a shortcut and not gather GMI again when they should have.
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#2140996 - 08/07/17 03:05 PM
Re: GMI on a different application
Bec
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TR, You could for B, but I don't believe that same allowance works for a HMDA reportable 'repeat' loan. But then, I already said that, didn't I. Simultaneous requests are an entirely different thing, though.
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#2141085 - 08/07/17 06:41 PM
Re: GMI on a different application
Bec
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Totally agree.
The reason I remarked again was due to this statement:
Even in the rare instances where a refinance is done at the same bank, we collect the GMI fresh for the refi rather than going back to the original even tho, as David pointed out above, we could.
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