Collecting Government Monitoring Information

Posted By: Arizona

Collecting Government Monitoring Information - 05/31/12 08:26 PM

Our marketing department would like to redesign our internal loan application to incorporate government monitoring information. We do not use FNMA 1003 for residential loan applications, we use our internal applications for every type of loan request. A separate form is used to collect gov monitoring info.
If the information is collected on the new application form and the loan request was not for a dwelling would there be any repercussions?
Posted By: ahkcompliance

Re: Collecting Government Monitoring Information - 05/31/12 09:01 PM

Do you have different applications for real estate secured and non-real estate secured?
Posted By: Arizona

Re: Collecting Government Monitoring Information - 05/31/12 09:06 PM

No same application used for every type of request.
Posted By: raitchjay

Re: Collecting Government Monitoring Information - 06/01/12 03:56 PM

Originally Posted By: Arizona
If the information is collected on the new application form and the loan request was not for a dwelling would there be any repercussions?


You definitely don't want to be routinely gathering GMI on loans not subject to the GMI requirements.
Posted By: ahkcompliance

Re: Collecting Government Monitoring Information - 06/01/12 04:08 PM

I agree you don't want to continually collect GMI when it is not needed. I would think examiners would frown upon this. I think your best option would be to either continue what you do now by using the seperate sheet or develop other applciations one for RE secured and one for Non RE secured.
Posted By: Dani York, CRCM

Re: Collecting Government Monitoring Information - 06/04/12 01:27 PM

Examiners will cite a Reg B violation if you collect GMI for any loan other than a loan to purchase of refinance a primary dwelling or that is covered by HMDA.
Posted By: #Just Jay

Re: Collecting Government Monitoring Information - 06/12/12 01:22 PM

Exactly... one app where it is collected incorrectly will most likely find it onto your exam as a finding.

Ensure you have strong training and controls in place going forward.