01/09/2012
We have a business entity purchasing a property to be used as a rental property. The loan officer obtained personal guaranties. For HMDA we know this is reportable as purchase. My question is about the GMI. Do we report this as business entity not applicable or do we need to report the GMI on the personal guarantees?
12/05/2011
I have a real estate loan that the customer checked on the GMI information that they do not wish to furnish this information. We are HMDA reportable. Do I use visual observation to complete the information on the LAR?
04/11/2011
Currently our policy is when we have a face to face application and only the applicant is in front of the loan officer, he/she marks the face to face box and the 3 boxes,( ethnicity, rate and sex) for the person in front of him/her. It is then our policy to contact the other applicant by phone and ask the GMI questions of the person that was not in front of the loan officer. Next the loan officer is to complete the GMI for that applicant (indicating he/she does not wish to furnish the information OR completing the 3 boxes) but write on the signature line that the information was taken by phone. Is that correct? Or on these face to face applications should we be completing the GMI information for the applicant that is not in front of the loan officer based on observations such as their last name or ask the applicant that is in front of the loan officer?
03/14/2011
I have read that if a loan is not HMDA reportable that you should not collect GMI. Is this the case. I know there is a difference between the Regs (B) and (C) and just want to be sure I am passing on accurate information.
10/25/2010
We have a residential loan in which the daughter's income does not qualify for the mortgage. We approved the loan with her father's income. The daughter is the only borrower and her father is the guarantor only. According to HMDA, getting it right, we need to report the incomes used to qualify the loan. However, they state the guarantor's GMI is not recorded? How do we best handle this?
08/09/2010
In compiling HMDA data, when can we use "information not supplied by applicant" and when are we required to "enter race or national origin and sex on the basis of visual observation or surname"?
05/17/2010
I am doing a purchase money HELOC. Can I collect government monitoring info, since home equities are not HMDA reportable?
05/10/2010
Should we put the HMDA worksheet in the loan file? Why don't we need to do a rate spread on commercial loans, but we still need to put the GMI in the file?
04/06/2009
In reading a response by Dan Persfull dated 7/7/08 titled "GMI on Refinance" he states that the definition of a refinancing applies whether you are refinancing one of your loans or a loan from another financial institution. However, if I read the definition of refinancing under Reg B - Supplement I (Official Staff Interpretations)it states the following: Sec. 202.13 Information for Monitoring Purposes 6. Refinancings. A refinancing occurs when an existing obligation is satisfied and replaced by a new obligation undertaken by the same borrower. A creditor that receives an application to refinance an existing extension of credit made by that creditor for the purchase of the applicant's dwelling may request the monitoring information again but is not required to do so if it was obtained in the earlier transaction. So do we collect it if we are refinancing the original purchase money from another financial institution or only if we financed the original purchase money?
03/23/2009
If part of the proceeds on a home equity loan are being used for home improvement, are we required to collect government monitoring information if we are not subject to HMDA reporting?