Skip to content
BOL Conferences
Forums · Active Threads · Forum Rules · Mark All Read · Log In
BankersOnline.com Forums Banker Forums HMDA Online GMI Collection
Thread Options
#2024138 - 06/30/15 06:19 PM Online GMI Collection
terpsfan Offline
Diamond Poster
Joined: Feb 2007
Posts: 2,059
How do you avoid customer's submitting monitoring information for non-HMDA loans? We include the notice in appendix B of reg B but it does not state when the customer does not complete the information.

Return to Top
HMDA

   
HMDA Academy
#2024139 - 06/30/15 06:20 PM Re: Online GMI Collection terpsfan
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Do you use the same application form for all loans? That can be a risky proposition for non-GMI loans.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#2024150 - 06/30/15 06:40 PM Re: Online GMI Collection terpsfan
terpsfan Offline
Diamond Poster
Joined: Feb 2007
Posts: 2,059
The application is the same for all online closed end mortgages. Our online application site does not have a way to only show the request for specific purposes.

Return to Top
#2024157 - 06/30/15 06:51 PM Re: Online GMI Collection terpsfan
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Could you have a separate application for different purposes? Or remove the GMI section and have a separate GMI form? I don't know how your system works but that is what I would explore to avoid a pattern and practice violation.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#2024218 - 06/30/15 09:15 PM Re: Online GMI Collection terpsfan
terpsfan Offline
Diamond Poster
Joined: Feb 2007
Posts: 2,059
Can we add some language stating the purposes that it should not be completed for? How do other online mortgage applications work because a customer could apply for a loan and put refinance as the purpose but not be refinancing any dwelling secured debt?

Return to Top
#2024222 - 06/30/15 09:29 PM Re: Online GMI Collection terpsfan
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 9,108
OK
If your applicant fills out the wrong application, it seems more defendable to me than if you have nothing but a catch-all application that includes the GMI for multiple purposes, some of which prohibit the collection of GMI. We're currently working on an online applications and creating a home equity type that would trigger the GMI only if HMDA criteria are met.
_________________________
I'm fixin' to fix that.

Return to Top
#2024236 - 06/30/15 10:38 PM Re: Online GMI Collection raitchjay
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Originally Posted By raitchjay
If your applicant fills out the wrong application, it seems more defendable to me than if you have nothing but a catch-all application that includes the GMI for multiple purposes, some of which prohibit the collection of GMI. We're currently working on an online applications and creating a home equity type that would trigger the GMI only if HMDA criteria are met.

And this would protect the bank if a customer made a mistake. The bank has a process to only gather when needed, the customer completed the form incorrectly, or changed their mind. No error by bank.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top

Moderator:  SMQ, CRCM