HMDA - GMI? LLC to be formed

Posted By: KMayotte

HMDA - GMI? LLC to be formed - 08/21/13 05:18 PM

Hoping someone can clarify for me ... here is the situation:

We had a customer interested in purchasing a multi-family dwelling. The customer indicated that he would form an LLC to hold title to the property - our Borrower would have been the newly formed LLC and the guarantor would have been the customer. Since the loan didnít close Ė it was declined Ė is GMI required for the customer (who would have been the guarantor) or the LLC to be formed? We donít have a formal application on file, just several e-mails between the lender and the customer where it was specifically noted that the new LLC would be the borrower. If the loan had booked, we would have completed the GMI based on the LLC. The letter of adverse action was mailed to the customer (guarantor).

Thank you,
Kathy
Posted By: TMatt87

Re: HMDA - GMI? LLC to be formed - 08/21/13 05:23 PM

Was this an actual application or just an inquiry?
Posted By: KMayotte

Re: HMDA - GMI? LLC to be formed - 08/21/13 05:40 PM

We didn't have a formal application - it came through the commercial lending department. It wasn't an inquiry; a notice of adverse action was sent.
Posted By: Dan Persfull

Re: HMDA - GMI? LLC to be formed - 08/21/13 07:00 PM

IMHO until the LLC was formed the individual was your applicant and you should have collected information based on that.
Posted By: KMayotte

Re: HMDA - GMI? LLC to be formed - 08/21/13 07:03 PM

Thank you, Dan. That's what we were leaning toward.