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#2213761 - 05/16/19 02:20 PM Government Monitor Information
mdog76 Offline
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Joined: Jan 2007
Posts: 645
Are banks allowed to collect govt monitoring info on construction to perm loans of primary residences since the reg says "or to be occupied"?

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Lending Compliance
#2213766 - 05/16/19 02:49 PM Re: Government Monitor Information mdog76
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,562
They are not just "allowed" to collect it, but required to collect it when it is a permanent loan. A construction-only loan would not require GMI since it is temporary, but a permanent loan (like a construction/perm) requires GMI collection.
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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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#2213767 - 05/16/19 02:50 PM Re: Government Monitor Information mdog76
mdog76 Offline
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Joined: Jan 2007
Posts: 645
Thank you!

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#2214717 - 05/31/19 07:10 PM Re: Government Monitor Information mdog76
Jenny Offline
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Joined: Oct 2015
Posts: 6
I have a similar question. Are you required under REG B (we are not HMDA reportable) to collect GMI when you are originating a new loan (primary residence) to pay off a construction loan that was used to build the primary residence? This is not a construction to perm loan.

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#2214718 - 05/31/19 08:06 PM Re: Government Monitor Information mdog76
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,364
Bloomington, IN
Yes.

(a) Information to be requested. (1) A creditor that receives an application for credit primarily for the purchase or refinancing of a dwelling occupied or to be occupied by the applicant as a principal residence, where the extension of credit will be secured by the dwelling, shall request as part of the application the following information regarding the applicant(s):
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The opinions expressed are mine and they are not to be taken as legal advice.

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