Beth - I have actually had a similar situation but the loan was denied. The individuals wanted to form an LLC specifically to hold the real estate asset they wanted to purchase and so it wasn't formed before the loan was denied. I submitted a question to CFPB HMDA Help and they called me back (nothing in writing of course!) and said that since the LLC was never formed, the individuals should be treated as the applicants. I asked about GMI - what if it wasn't collected because the LO assumed the applicant was an LLC? The individuals never heard the GMI "speech" and the application was not taken face to face?? Would I report as "Information Not Provided by Applicant"? They said to report the individuals as the applicants and GMI as "Information Not Provided by Applicant". Hope this helps.