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#2192148 - 09/11/18 03:05 PM
GMI
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Joined: Apr 2016
Posts: 364
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If we did not provide the customer with the new GMI options, just the old ones on the 1003, then we do report what is marked on the 1003? Or do we report as not provided? Or what is the best practice in these cases? The loan has already originated.
Last edited by George; 09/11/18 03:05 PM.
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#2192151 - 09/11/18 03:10 PM
Re: GMI
George
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Joined: Sep 2010
Posts: 2,670
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Were these applications taken in 2018?
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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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#2192152 - 09/11/18 03:12 PM
Re: GMI
George
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#2192159 - 09/11/18 03:31 PM
Re: GMI
George
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There's really not a good answer for you. The GMI form you used wasn't compliant. However, i certainly wouldn't choose the "not provided" option...they did provide....they provided on the form you gave them.
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#2192176 - 09/11/18 04:13 PM
Re: GMI
George
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Joined: Apr 2016
Posts: 364
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Hmmm...you're right, not a good answer haha. Thank you for your help!
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#2192184 - 09/11/18 04:35 PM
Re: GMI
George
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We get lots of write-ins...particularly for our Indian (Native American) borrowers.
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#2192187 - 09/11/18 04:46 PM
Re: GMI
Truffle Royale
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Joined: Sep 2010
Posts: 2,670
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I'm beginning to get concerned that not having more may be a flag for examiners. That was my first thought when I was reading your post, Truffle. I've known too many lenders who, for some reason, seem afraid to ask GMI questions and just mark the information without ever asking for it.
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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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#2192188 - 09/11/18 04:48 PM
Re: GMI
raitchjay
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Joined: Sep 2010
Posts: 2,670
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There's really not a good answer for you. The GMI form you used wasn't compliant. However, i certainly wouldn't choose the "not provided" option...they did provide....they provided on the form you gave them. I agree with raitchjay. You have a violation for not asking for all of the information, but I don't think you have any other option than to report what was provided.
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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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#2192193 - 09/11/18 05:08 PM
Re: GMI
raitchjay
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Joined: Nov 2002
Posts: 20,656
The Swamp
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We get lots of write-ins...particularly for our Indian (Native American) borrowers. We had a write-in RACE of German recently. Yeah, no way to really make that one work.
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#2192195 - 09/11/18 05:33 PM
Re: GMI
George
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Joined: Oct 2009
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Yeah, we sort of fought a world war over that concept...LOL.
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#2192204 - 09/11/18 06:44 PM
Re: GMI
Truffle Royale
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Joined: Sep 2004
Posts: 5,249
out of the frying pan...
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Side bar: I'm curious how many are getting more than the same three answers we've always been getting. I'm not seeing much by way of additional answers beyond what was on last year's LAR. I'm beginning to get concerned that not having more may be a flag for examiners.
We get the occasional expanded answer, but mostly it's the same old 3.
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#2192214 - 09/11/18 07:12 PM
Re: GMI
RR Becca
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Joined: Apr 2013
Posts: 420
VA
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Side bar: I'm curious how many are getting more than the same three answers we've always been getting. I'm not seeing much by way of additional answers beyond what was on last year's LAR. I'm beginning to get concerned that not having more may be a flag for examiners.
We get the occasional expanded answer, but mostly it's the same old 3. We have yet to get an expanded answer. I have the same worry as Truffle.
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#2192222 - 09/11/18 07:40 PM
Re: GMI
George
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Joined: Oct 2009
Posts: 9,232
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I don't see how/why it would be a red flag. You can't make your applicants spend more time on the DI section than they want to, and a lot of people (my aforementioned customers notwithstanding, evidently) aren't interested in expounding on their race evidently.
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#2192234 - 09/11/18 08:04 PM
Re: GMI
George
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Platinum Poster
Joined: Jan 2017
Posts: 615
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If examiners look at the data and next year and some percentage of applicants in a certain situation provide expanded data, and 0% provided it at your institution (Or internally, if one particular lender is never getting expanded data), I could see that being a flag that your lender(s) might not be asking applicants and are just filling it in themselves.
On the other hand, if the industry as a whole is seeing that nobody is providing this information, then the regulators have a nice indication of how useful the expanded fields really are. Time will tell.
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#2193312 - 09/21/18 01:22 PM
Re: GMI
Truffle Royale
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100 Club
Joined: Oct 2015
Posts: 211
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Truffle - 9 months in and I haven't seen a single write-in yet. That being said, we also are not in a very diverse area. A very strong majority of persons in our area would all fit into one demographic, for which there are no write-in boxes.
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#2193570 - 09/24/18 06:01 PM
Re: GMI
George
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New Poster
Joined: Jul 2014
Posts: 14
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I've seen on average 1 write in per 500 applications. Most of those are if the borrower sent in the application. If the lender took the application by phone than only 3 boxes are checked. I don't think most LO's bother explaining or asking for the extra fields.
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#2193575 - 09/24/18 06:17 PM
Re: GMI
DunningKroger
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Joined: Jul 2003
Posts: 17,410
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I don't think most LO's bother explaining or asking for the extra fields. Agreed, and hence my concern.
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#2193622 - 09/24/18 10:50 PM
Re: GMI
George
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Joined: Aug 2006
Posts: 4,266
Chillin an grillin
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We get write-ins for American Indians and we get Asian Indian, Chinese and Mexican applicants. Not TONS but we are getting responses.
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#2196753 - 10/29/18 09:24 PM
Re: GMI
George
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Junior Member
Joined: Mar 2014
Posts: 47
OK
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We've had a few expanded race or ethnicity, but we've had a lot more applications with the "I do not wish to provide" boxes checked, especially on the internet applications for our mortgage department. Some of the "I Do Not Wish to Provide" applicants will check the applicable box for gender, but not for race or ethnicity...
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#2196896 - 10/31/18 03:00 AM
Re: GMI
Truffle Royale
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Member
Joined: Aug 2017
Posts: 62
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I don't think most LO's bother explaining or asking for the extra fields. Agreed, and hence my concern. Or completing the form right. We have had some write-ins. We do have a bunch of sub-category designations under Asian. My favorite "bang my head against a wall moment" was when I had to confirm whether the write-in of "Filipino" under Other Pacific Islander was because the borrower didn't identify as an Asian-Filipino but instead purposefully identified as an Other Pacific Islander Filipino. It was a telephone application so I wasn't sure if it was a purposeful identification or an LO mistake. I'm sure you can guess which one was correct.
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