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Business Borrower with Cosigners - GMI?

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HMDA - We have a business loan to three borrowers to purchase a 1-4 family dwelling for investment purposes. One of the borrowers is a formal business entity, and the other two are the two individuals that own the business. The business entity is the primary borrower, but the individuals also sign on the note individually. We are not clear regarding the issue of reporting monitoring information in such a case -- we have had much discussion, and have done much research about this and can't come up with a consensus. In situations where you have a business entity borrowing, AND you also have individuals signing individually on the note, should you report monitoring information on one, or both of the individuals since they are individually signed on the note also? In such a situation would we show the monitoring fields on the applicant, i.e. the business entity as NA, and show monitoring information on one of the individuals under the co-applicant fields? Any guidance you could provide would be greatly appreciated.

Always report GMI on the primary applicant. If more than one co-applicant, report GMI on the co-applicant first listed.

First published on 2/13/06

First published on 02/13/2006

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