Entity to be determined on withdrawn HMDA loan

How do we report GMI and other entity fields for HMDA when the applicant was "entity to be determined"? Do we just treat it as an entity even though we don't have a name and the entity was not created or do we treat is as the person who requested the loan was the applicant?

Thanks much! Never a dull day with HMDA around.

Did a person apply individually or was it an entity applying?

Sounds like an individual planning to create an entity so the entity would be the borrower. They haven't completed the process to create the legal entity yet. It sounds like this happens more often in commercial as the customer wants to make sure they are approved for a loan before going through the expense of creating the new entity.

Beth - I have actually had a similar situation but the loan was denied. The individuals wanted to form an LLC specifically to hold the real estate asset they wanted to purchase and so it wasn't formed before the loan was denied. I submitted a question to CFPB HMDA Help and they called me back (nothing in writing of course!) and said that since the LLC was never formed, the individuals should be treated as the applicants. I asked about GMI - what if it wasn't collected because the LO assumed the applicant was an LLC? The individuals never heard the GMI "speech" and the application was not taken face to face?? Would I report as "Information Not Provided by Applicant"? They said to report the individuals as the applicants and GMI as "Information Not Provided by Applicant". Hope this helps.