Those are good points. I think I have in my notes to do this, but glad you all brought it back up.
We plan on doing a 'scrub' of our loans in process as of 12/29/2017 and any that are going to close in 2018 that will BECOME HMDA reportable, we will get that GMI disclosure to our customers. Not sure if calling the customer is going to be the method or what?
Compliance - A Painful Addiction
All comments are mine & should not be taken as legal advice.