GMI COLLECTED ON NON HMDA REPORTABLE LOAN

: Confused in NY:
Scenario - application is received for what would typically be a HMDA reportable loan (Refi of a dwelling to be the primary residence of 1 family). GMI is collected. Later down the road in the process, it is determined that this will be a Consolidation / Modification of the existing loan. CEMAs (otherwise known as MECAs) are not HMDA reportable (unless for the purpose of purchase or Home Improvement). Now I have an application for a loan that is not HMDA reportable but we have collected the GMI. Should a notation be made on the application that the GMI was collected in error?

Well, it wasn't in error when it was collected. I would note the file that the loan type changed.

From the Commentary of Regulation B:

Official Interpretations of this section.
Section 1002.13—Information for Monitoring Purposes

13(b) Obtaining of information.

For some reason, auditors and examiners have convenient amnesia when they find GMI in a non-reportable dwelling secured loan. Be sure to copy the above item from the Commentary (complete with the regulation section cite) in your notation in the file.

This wasn't even inadvertent. It changed to a modification.

Kathleen is correct, it wasn't inadvertent. But your feedback has cleared the fog from my brain. Thank you all for your responses and feedback.