Posted By: Denny

HMDA - 06/07/06 01:20 PM

If the Bank CSR takes a loan application that's HMDA reportable but the CSR doesn't recognize it as such at that time, what is the best way of getting the IGMP information six months later so the loan can be entered onto our HMDA LAR? Also, if the loan is denied making the IGMP almost impossible to obtain, should the loan still be reported on the LAR and if so how should the ethnicity, race and sex fields be coded? Any suggestions/help is appreciated.
Posted By: Roger That

Re: HMDA - 06/07/06 01:24 PM

I assume this was face/face?
Posted By: Denny

Re: HMDA - 06/07/06 01:31 PM

No, it was a phone application
Posted By: Roger That

Re: HMDA - 06/07/06 01:35 PM

Well, you have 2 choices: 3/6/3 - applican(s) chose not to provide, and report as such - or, the applicant(s) chose to respond to the Gov't mont questions.
Posted By: Denny

Re: HMDA - 06/07/06 01:53 PM

Thanks for your help Rictus. If the application was taken face-to-face, what is your suggestion as to how to code the IGMP info?
Posted By: omanrock

Re: HMDA - 06/07/06 02:01 PM

There are a few issues here:

1. If the loan is HMDA-reportable, it should be reported on the LAR regardless of final action (whether it funds or is denied).

2. If the application was taken by phone, the lender is still required to request the information from the applicant, and the applicant chooses whether to furnish it. If you automatically code the GMI 3/6/3 without having requested it from the applicant, the record will be in violation.

3. By "six months later", does that refer to six months after the application date or the denial date? All records are required to be entered onto the LAR within 30 days following the end of of the quarter in which the denial occurred.

Hope this helps - good luck...
Posted By: Denny

Re: HMDA - 06/07/06 02:23 PM

Omanrock, I know we could be cited for not reporting the loan in a timely manner but my question is: should we still enter the loan on our LAR and if so how do we code the IGMP?
Posted By: Truffle Royale

Re: HMDA - 06/07/06 02:40 PM

omanrock is right...up to a point on #3. Yes, records are required to be entered within a certain time frame. But if you find one that was inadvertantly left out, enter it! whether it's six weeks or six months later, as long as it makes it on that year's LAR.

In the past, on loans that did not have the gmi for whatever reason, I've tried calling but I find sending a letter stating that " order to comply with Government Regulation C, (we) are required to obtain the following information concerning your recent loan application at our bank" to be more effective. I request the applicant complete the Section X info and return to me in the enclosed SASE. I document by keeping a copy of the letter in the file showing my good faith attempt to correct the ommission error.
Posted By: omanrock

Re: HMDA - 06/07/06 02:46 PM

Yes I agree - I should have clarified. If final action on this record was taken in 2006, it should be entered onto the 2006 LAR.
Posted By: Dan Persfull

Re: HMDA - 06/07/06 03:14 PM

IMO, follow TR's advice. If they don't return the letter then mark the application that the information was not furnished. However this only works for non face to face applications. For face to face applications you are required to note the GMI based on visual observation and/or surname.

Click here for a sample letter.
Posted By: Denny

Re: HMDA - 06/07/06 04:45 PM

Thanks Dan. Your letter is very helpful. Thanks everyone for your help.