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#2165471 - 02/22/18 06:14 PM GMI and On-line application
Winning Offline
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Joined: Sep 2015
Posts: 88
I have an application that was provide on-line. The application says such. The GMI info is filled in. Should we be filling in the "xxxx was collected based on visual observation or surname" as a NO? On our applications it says (collect if a face-to-face transaction). If we don't choose NO..what do we put?

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#2165476 - 02/22/18 06:34 PM Re: GMI and On-line application Winning
Monster Offline
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Joined: Sep 2015
Posts: 500
IMHO - it is not applicable (and should be reported on the LAR as such) since it was not a face to face transaction.

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#2165483 - 02/22/18 07:06 PM Re: GMI and On-line application Monster
Truffle Royale Offline

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Joined: Jul 2003
Posts: 17,400
^^^Kathleen Blanchard spoke to CFPB on this and posted to it in another thread in this forum.
You only complete the questions for face to face applications.

Then you get into the whole discussion about coming face to face at any time during the "application process".

Consistency is key, imho. here's one of the threads in question

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#2165485 - 02/22/18 07:07 PM Re: GMI and On-line application Winning
Winning Offline
Member
Joined: Sep 2015
Posts: 88
would I enter N/A for ALL applications that were NOT taken face-to-face?

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#2165496 - 02/22/18 07:53 PM Re: GMI and On-line application Winning
Truffle Royale Offline

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Joined: Jul 2003
Posts: 17,400
imho, yes.

Remember my caveat about 'during the application process'.
I am not a front line bank so it's easier for me to put the stop sign up.

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