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#2175553 - 04/27/18 02:18 PM conflict re: GMI
Catm1991 Offline
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Joined: Jul 2014
Posts: 194
MO
I need some added wisdom....If we receive an application that customers have completed, signed, dated it and all GMI is filled out and they meet with the loan officer, etc. etc.

In reporting the GMI I would think it would be reported as... not collected on the basis of visual observation or surname.

Wouldn't this be correct?

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#2175555 - 04/27/18 02:20 PM Re: conflict re: GMI Catm1991
GTS333 Offline
Gold Star
Joined: Jun 2010
Posts: 257
Yes, if the consumer provided you with their GMI that's right. You only identify it as being based on VoS if they declined to provide, and your loan officer then used VoS to guess Race/Ethnicity/Sex.
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My opinion, take it for what its worth. Opinions expressed are my own and not those of my employer and are not legal advice.

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#2175556 - 04/27/18 02:28 PM Re: conflict re: GMI Catm1991
raitchjay Online
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Joined: Oct 2009
Posts: 9,086
OK
If the application was taken face-to-face, then for sure, yes, report it as not collected on the basis of visual observation or surname. If it was received some other way, i believe there are 2 schools of thought...report it that way, or (as my software wants, and i believe the more accepted view) is to report that as NA.
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#2175562 - 04/27/18 02:34 PM Re: conflict re: GMI raitchjay
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,658
I agree with the others. You would only list that the information was collected on the basis of visual observation or surname if the applicant did not provide the information and your loan officer had to make a visual observation in a face-to-face interview. If they did provide the information, you did not collect it based on a visual observation.
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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