GMI

Posted By: dac

GMI - 04/28/15 07:31 PM

The bank is doing a Demand loan for 12 months. The source of repayment is another loan from us so this loan is not HMDA reportable. Do we need to collect GMI because the loan is to purchase a real estate investment? Condo unit
Posted By: David Dickinson

Re: GMI - 04/28/15 07:47 PM

If it's not HMDA reportable, you can forget GMI collection under HMDA. The only other regulatory requirement to collect GMI is Reg B's §1002.13 but that section only applies to the purchase or refinancing of a principle dwelling. If it's a real estate investment, it sounds like it doesn't qualify. Therefore, you should not collect GMI.