Posted By: mdog76
Government Monitor Information - 05/16/19 02:20 PM
Are banks allowed to collect govt monitoring info on construction to perm loans of primary residences since the reg says "or to be occupied"?
Posted By: Adam Witmer
Re: Government Monitor Information - 05/16/19 02:49 PM
They are not just "allowed" to collect it, but required to collect it when it is a permanent loan. A construction-only loan would not require GMI since it is temporary, but a permanent loan (like a construction/perm) requires GMI collection.
Posted By: Jenny
Re: Government Monitor Information - 05/31/19 07:10 PM
I have a similar question. Are you required under REG B (we are not HMDA reportable) to collect GMI when you are originating a new loan (primary residence) to pay off a construction loan that was used to build the primary residence? This is not a construction to perm loan.
Posted By: Dan Persfull
Re: Government Monitor Information - 05/31/19 08:06 PM
Yes.
(a) Information to be requested. (1) A creditor that receives an application for credit primarily for the purchase or refinancing of a dwelling occupied or to be occupied by the applicant as a principal residence, where the extension of credit will be secured by the dwelling, shall request as part of the application the following information regarding the applicant(s):