Is it a violation to collect that information if we use a standard URLA for our consumer transactions?
It would be a violation for collecting the information, not using the application. However, regularing using the application that request the DI for those transactions would jeopardise any defense you may have that the information is inadvertently being collected.
From 1002.13(b) - 6. Inadvertent notation. If a creditor inadvertently obtains the monitoring information in a dwelling-related transaction not covered by § 1002.13, the creditor may process and retain the application without violating the regulation.
If you are going to regularly use the application for "exempt" transactions then the key will be to have all persons taking an application to be fully trained for when they are to collect the DI.
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The opinions expressed are mine and they are not to be taken as legal advice.