Section 202.13 states "we must collect monitoring information for credit primarily used for the purchase or refinancing of a dwelling occupied by the applicant as a principal residence." We have a customer whose loan we are refinancing with the initial purpose of home improvement. Does this refinancing count for monitoring information purposes? I tried to find a definition of refinancing but was unsuccessful. Thanks in advance for your assistance.

You may also want to check out your HMDA guidelines. You will collect data only in the following 3 scenarios:

1. Dwelling-secured loan used to purchase a dwelling
2. Dwelling-secured loan used to refinance a dwelling (you must pay off and satisfy the lien)
3. Dwelling-secured loan used to perform Home Improvement

Thankfully we are not a HMDA reporting bank so I am clueless to those guidelines.

If you are not a HMDA bank, the refinancing of a home improvement loan, whether or not secured by real estate, does not require (or allow) collection of GMI.

I was doing some review of some material I had regarding collecting monitoring information for REG B. In the list it noted bridge loans as being applicable. I honestly do not know where this came from and just wanted to confirm that it would not be required on a bridge loan. Reg B does refer to an exemption for temporary financing, but could there be an instance where Reg B would apply to a bridge loan? I've seen "bridge" loans secured by both the new dwelling and the current dwelling. If the loan is to help purchase the new dwelling secured by the new dwelling, why would it not apply? Thanks!

Are you stating that a bridge loan is considered a purpose other than purchase so the Reg B monitoring does not apply? Thanks.

No I didn't say that. A bridge loan could or could not be subject to the GMI collection requirements under 202.13. It will depend what dwelling(s) are securing the bridge loan.

So in the example above, Reg B monitoring information would be collected on a bridge loan to purchase a dwelling secured by the dwelling being purchased. Would that be a correct statement? I'm trying to finish up revising some training material and just want to be sure I've stated this correctly. Thank you for your help.

Any loan, with the exception of a temporary construction loan, is subject to the Reg. B GMI data collection requirements if the loan is to purchase, or refinance the purchase of the applicant's primary dwelling and will be secured by that dwelling. Construction/permanent loans are subject to GMI data collection requirements.

1. Bridge loan secured by the primary dwelling being purchased. Collect GMI.

2. Bridge loan secured by the current/existing primary dwelling to purchase a new primary dwelling. Do not collect GMI.

3. Bridge loan secured by the current/existing primary dwelling to purchase a new primary dwelling and also secured by the new primary dwelling. Collect GMI.

Dan - thank you so much, this is a great help!