700K home-1st mtg 450,000 and 2nd mtg 250,000. Simultaneous loans with 1st mtg sold to 2ndary market investor. Question is, would the 2nd mtg also be reportable since both loans were closed on the same day to purchase home? Bank holds the 2nd in portfolio 62 months.

Yes, the 2nd lien loan is also reportable as a purchase.

Remember this: Lien position is never a factor in whether an application is reportable or not.

Yes, David! I did keep hearing that echo in my muddled compliance brain, but for some reason that's a hard one for me to remember. Thanks to both of you for all of your help!

On this note, would it be a violation if monitoring information was not collected on the 2nd mortgage...or is collection of monitoring information on the 1st mortgage only acceptable?

If the loan was used to purchase then the monitoring information should have been collected at application. Yes, it would be a violation.

Did you do the applications at the same time? If so, you collected the gmi and can transfer it to the second application.

Excellent point, Truff! I didn't think of that.

They marked it out as "Collected in error"..on the 2nd mortgage

So you had 2 application forms: On both, GMI was collected, but it was crossed out on the 2nd lien application?

Yes, not sure why, but then I'm just the auditor.

First, they could have used 1 application form and made 2 loans from it. You need GMI for both (as previously discussed). You have the GMI, so no problem, but when it was crossed out on the 2nd application form, it basically says they don't understand.

Yes, and evidently neither do I! Additional training is in store for me and them! Thank you for your help.