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#2254034 - 05/18/21 03:01 PM GMI information on the Application
kmenard Offline
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Joined: Oct 2014
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We are working with a new LOS and it appears that when GMI information is collected application it is not appearing on the application. It is part of the application process in the system but does not print on the actual application. The GMI information shows on the "Loan Summary" page. Is the GMI information required to be on the application that the customer signs?

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#2254037 - 05/18/21 03:20 PM Re: GMI information on the Application kmenard
rlcarey Offline
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Galveston, TX
What sort of application are you producing. It should be Section 8 of the Borrower Information on the URLA.
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#2254038 - 05/18/21 03:22 PM Re: GMI information on the Application kmenard
kmenard Offline
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This is on Home Equity Loans.

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#2254043 - 05/18/21 03:47 PM Re: GMI information on the Application kmenard
rlcarey Offline
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Galveston, TX
Then how is it originally collected and are you required to report HELOCs on your LAR?
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#2254056 - 05/18/21 05:54 PM Re: GMI information on the Application kmenard
kmenard Offline
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Joined: Oct 2014
Posts: 55
We do not take "paper" applications. Everything is taken on the computer while having conversation with the applicant. After the "interview" is completed, the application is printed and the applicant will initial the Reg B disclosure and sign the application. The application in question are HE loan application that will coded as "Other".

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#2254070 - 05/18/21 07:04 PM Re: GMI information on the Application kmenard
rlcarey Offline
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rlcarey
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Galveston, TX
So you read them the whole preamble to the demographic information request and they then provide it orally and you document it. I guess that is a business decision. Seems like a big waste of time and have dangers of LOs not doing it properly.
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#2254089 - 05/18/21 10:43 PM Re: GMI information on the Application kmenard
kmenard Offline
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Joined: Oct 2014
Posts: 55
That is correct and I agree with you. So the question is, does the GMI information have to be on the printed application?

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#2254093 - 05/19/21 11:33 AM Re: GMI information on the Application kmenard
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,562
Originally Posted by kmenard
So the question is, does the GMI information have to be on the printed application?

Well, there are three things to consider.

First, Regulation B does not require the information to necessarily be on the application form. See comment 1 to 1002.13(b):

13(b) Obtaining of information.
1. Forms for collecting data. A creditor may collect the information specified in ยง 1002.13(a) either on an application form or on a separate form referring to the application.


Secondly, Regulation C (HMDA) does not require the information to only be on the application form. See Appendix B to Regulation C:

You may list questions regarding the ethnicity, race, and sex of the applicant on your loan application form, or on a separate form that refers to the application.

Finally, you would need to check with your investor if you sell loans on the secondary market as some may require it to be on the application form itself.

All of that said, it seems like you have a system quirk/incorrect setting if the Demographic Information is not listed on the application form for only home equity (other) purpose, HMDA reportable loans. If you are a HMDA reporter, there is no reason why this information would be excluded for HMDA loans (it would be for Reg B, but HMDA overrides the requirement and requires the information). Therefore, I would contact your LOS as it seems something is wrong with your settings - they may have you set up as a non-HMDA Reg B only bank, rather than a HMDA reporter.
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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.
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