Reg C, HMDA will go into effect 1/1/04 with new race and national origin categories. When should the application show the new questions considering applications taken prior to 1/1/04 could close after the effective date?

You are going to need it for reporting purposes so start collecting it prior to 1/1/04.

I have not seen any prohibition on when to start collecting, just that the data needs to be included in 2004 reporting.

I believe rules on the transition are being formulated. The comment period ended a month or so ago, so guidance will be forthcoming.

The Fannie Mae announcement regarding the revised 1003 states "The revised Uniform Residential Loan Application will be required for applications taken on and after January 1, 2004 and may not be used prior to that date".

We'll have to wait for the final transition rules to see how to report information gathered in 2003 and reported in 2004.

I hope thar Fannie May is right. If you decided to collect under the New GMI rules for loans that you thought would close in 2004, what do you do with loans that close too early? What about loans that get delayed and close in 2004, yet you didn't get the new GMI for the applicants?

It only makes sense to begin using the new GMI forms on 1/1/04, not before. We will have to have some guidance for converting the old race categories to the new ones (what do you do with "other") for applications taken in 2003 and closed in 2004.