So the question is, does the GMI information have to be on the printed application?
Well, there are three things to consider.
First, Regulation B does not require the information to necessarily be on the application form. See comment 1 to 1002.13(b):
13(b) Obtaining of information.
1. Forms for collecting data. A creditor may collect the information specified in § 1002.13(a) either on an application form or on a separate form referring to the application.Secondly, Regulation C (HMDA) does not require the information to only be on the application form. See Appendix B to Regulation C:
You may list questions regarding the ethnicity, race, and sex of the applicant on your loan application form, or on a separate form that refers to the application.Finally, you would need to check with your investor if you sell loans on the secondary market as some may require it to be on the application form itself.
All of that said, it seems like you have a system quirk/incorrect setting if the Demographic Information is not listed on the application form for only home equity (other) purpose, HMDA reportable loans. If you are a HMDA reporter, there is no reason why this information would be excluded for HMDA loans (it would be for Reg B, but HMDA overrides the requirement and requires the information). Therefore, I would contact your LOS as it seems something is wrong with your settings - they may have you set up as a non-HMDA Reg B only bank, rather than a HMDA reporter.