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#2269631 - 04/26/22 03:13 PM Collecting GMI for TBD Address
Wonderofitall Offline
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Wonderofitall
Joined: Sep 2010
Posts: 174
Out West
Applicant submitted a mortgage application for purchase of a primary residence and included their GMI. We have an external audit finding that GMI should not have been collected for an application for a purchase of a primary residence where the applicant listed TBD as the address because without an address it's not an application for a residential loan. Loan app indicated the purpose was for purchase of PR.

Does lack of an address nullify the Reg. B requirement for collecting GMI?
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Lending Compliance
#2269634 - 04/26/22 03:16 PM Re: Collecting GMI for TBD Address Wonderofitall
InFairness, CRCM Offline
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InFairness, CRCM
Joined: Nov 2010
Posts: 648
USA
Was this a pre-approval program? If so, it is an application for a residential loan under HMDA and GMI collection is a requirement.
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#2269635 - 04/26/22 03:27 PM Re: Collecting GMI for TBD Address Wonderofitall
Wonderofitall Offline
100 Club
Wonderofitall
Joined: Sep 2010
Posts: 174
Out West
We don't have a pre-approval program. This was just an applicant submitting a URLA without an address.
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