09/04/2006
We have a loan request to purchase a residence that will be the primary residence for one borrower but there is a co-borrower that will not occupy the home. Do we collect government monitoring information for all borrowers or just the borrower that will occupy it as their primary residence?
07/10/2006
This question is regarding Reg B and HMDA, are there any instances when the ethnicity, race, and sex information should be collected for Reg B purposes, but not HMDA purposes (for instance, lines of credit with a primary purpose of purchasing or refinancing a principal dwelling)? Is it okay to collect the government monitoring information in these cases even if the loan is not HMDA applicable?
03/13/2006
We receive most of our business from brokers, and most applications are received mainly via fax and internet. I came across some partial GMI information where the customer left some boxes blank, but they did check the sex box. In other instances, the customer checked off the I Do Not Wish to Furnish, and proceeded to check off the sex box, or other boxes, but not all of them. Keep in mind that we have little, and in most cases, no contact with the customer since they are all referred by our brokers. Should we report these as information not provided all across the board, or should we put not provided for the information not provided, and fill in the information that the customer did in fact, check off?
02/27/2006
Does GMI need to be collected in a consumer real estate transaction when the borrower is a trust?
01/23/2006
My question is regarding applications for construction loans. If the customer comes in and picks up a mortgage application, then brings it back to the bank and it happens to be a construction loan, but the customer has now filled in the government information, can we be in violation because the information was collected when it was not required? Even though the customer voluntarily provided the information? I have heard from others that having the information when not required is worse than not getting it at all. We use "Mortgage Applcation Brochures" which we have in our lobbies that our customers can pick up and take home with them to complete. It gives them the instructions, an application, required items checklist, servicing disclosure, and a general release. But what we are finding is they are taking it home and completing it and we don't know that they are applying for a construction loan. What was suggested was to make up a "Construction Application Brochure" with the government section crossed out. What is the penalty of the customer filling out the information voluntarily? And also what is the best solution to our "application brochures"?
12/05/2005
If an application for the purchase of a primary residence has a joint applicant that is a non-occupant, is the bank required to collect the government monitoring data from the non-occupying borrower or just the occupying borrower?
07/18/2005
How do you report a HMDA loan with four borrowers when the LAR only has space for applicant and co-applicant?
02/21/2005
When the borrower signs the 1003 for government monitoring purposes and checks the box for "I do not wish to furnish this information," but also checks the boxes for ethnicity and race, how does this get reported?
01/17/2005
Can you collect the government monitoring information on a construction loan application? Our construction department uses the regular 1003 form, but I thought you could not collect this information for construction loans.
10/18/2004
When is the government monitoring information not required?