How should a Bank complete the HMDA DMI form when a broker took the application and the Loan Officer does not see the customer until closing? If the broker is responsible for completing the DMI form per 1002.2 definition of "referrals to creditors", how would the Bank report that information? As "information not provided"? Or does the Loan Officer reach back out to the customer prior to closing?

You've a couple of different choices but honestly, I'd be getting on the broker and telling them they must, by law, get the information or indicate the application was taken either by fax, mail or internet and intentionally left blank by the applicant. For f2f or telephone, the broker must be asking and completing. That's what we do with LOs who don't complete the DMI and usually, after a time or two, they get the message and do it right the first time.