Often times a commercial lender will sit across from a client and discuss their needs, either onsite, offsite, etc....the client might indicate that they are looking for a loan to finance an apartment building for example. Sometimes the conversations are formal some are more casual.
If the client indicates that they are looking for a loan, the lender would probably leave them with a PFS or a Business Banking application to be completed. In some commercial settings the lender is not going to sit with the applicant and have them complete the PFS or Business Banking application for the credit request...so the client will complete at a later date and drop off at the bank. (in other cases, the lender may sit across from the applicant and complete, those are straight forward - face to face application collect GMI at that time if HMDA reportable).
In cases, where the lender leaves a PFS or Business application to be completed later by the applicant, is this considered a face to face application, because the lender had those initial discussions and left the pfs or business banking application. Or is this considered a mailed in application since the borrower completed and dropped off at the bank at a later date.
When should the lender ask for GMI. If the lender knows that the borrower is looking to finance a HMDA reportable loan, should they leave the GMI data collection sheet with the PFS or business application. If they do not, would it be okay for the lender's admin to follow up to obtain GMI information once we receive the PFS or application back at the Bank. If this is permissible, and the admin calls the applicant (is this really a telephone application or would it be a face to face since the lender originally met with the applicant). If it's face to face and the applicant chooses not to provide, I would assume the lender would then need to document based on visual observation.
Because commercial and business banking application processes are different from retail, we are trying to determine how to handle. I realize this isn't anything new. I'm asking because we are implementing a new commercial system and basically the lender brings the info back to the admin to input into the system....so we are looking at procedural changes.