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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