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#683861 - 02/09/07 02:53 PM Monitoring Info on phone applications - Not HMDA
OnTheEdge Offline
Diamond Poster
Joined: Apr 2002
Posts: 1,677
SmallTown, USA
I've moved form HMDA reporting bank to one that is not. I have forgotten, do we need to request monitoring info on phone applications?
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Lending Compliance
#683868 - 02/09/07 03:00 PM Re: Monitoring Info on phone applications - Not HMDA OnTheEdge
Jerod Moyer Offline
Platinum Poster
Jerod Moyer
Joined: Oct 2005
Posts: 667
Sioux Falls, SD
Monitoring information is required to be collected at the time of applicaiton; therefore, if you take an application over the telephone you must request the information over the phone.
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Jerod Moyer
www.bankerscompliance.com

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#683950 - 02/09/07 03:44 PM Re: Monitoring Info on phone applications - Not HMDA Jerod Moyer
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,858
Bloomington, IN
If you are not subject to HMDA reporting then you must collect monitoring information under the provision of Reg. B's 202.13. You are to collect monitoring information if the loan is for the purchase of the applicant's primary residence, or the refinancing of the purchase of the applicant's primary residence and the loan will be secured by that residence. Otherwise you would not collect monitoring information, such as a loan for consolidation purposes.
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The opinions expressed are mine and they are not to be taken as legal advice.

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