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#906976 - 02/19/08 09:22 PM GMI - customer doesn't provide
KTMiteComply Offline
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KTMiteComply
Joined: Jul 2007
Posts: 3,298
only if I want to....
We have a loan file in which the initial and final application is checked I do not wish to furnish GMI Information. On the LAR, we have entered the codes (3,6) that information was not provided by applicant for Ethnicity and Race and we entered the code 1 (male) for gender. The applicant’s Driver’s License is in the file and the application was taken by telephone. I am looking at Appendix B to Part 203. It says if the applicant chooses not to provide the information for an app taken in person, we should note the fact and then basically complete the information the best we can based on visual observation and surname but if app is taken by phone we need not provide the info and mark that the app was taken by phone, etc. The Driver’s License in file is what is confusing me – should we use them to make best determination and complete the GMI information or should we follow instructions based on telephone app in Appendix B?
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#907244 - 02/20/08 03:19 PM Re: GMI - customer doesn't provide KTMiteComply
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
When and how was the DL obtained? If you met with the applicant anytime during the application process then you are required to request the information once again and if not provided report based on visual observation.

If the only time you met with the applicant is at the closing table then everything should be reported as provided by the applicant.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#907282 - 02/20/08 03:41 PM Re: GMI - customer doesn't provide Dan Persfull
KTMiteComply Offline
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KTMiteComply
Joined: Jul 2007
Posts: 3,298
only if I want to....
Most of the time we obtain a copy of the driver's license before we close as well as at the closing table by the attorney's office, however there have been times when it was obtained only at the closing table.

I have really struggled back and forth over this one b/c my thinking was what is the difference if they are sitting across from you face to face and they do not want to provide the info and you mark it based on a visual and having a picture and you mark it based on a visual?

I really appreciate your advice!
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Trust in the Lord with ALL your heart...Prov 3:5-6

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