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Collect GMI Info or Treat as Business?

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Question: 
I have a question regarding HMDA. I am doing a business loan to a dentist, Joe Dentist, DDS and the purpose is a refinance of existing debt secured with his principal residence. Do I collect GMI information and report his race, sex, ethnicity and income or treat as a business and report as 4,7,4 & N/A?
Answer: 

If the dentist is borrowing as an individual, you will report GMI and the income used in the credit decision. If his practice is set up as an entity (an LLC, professional corporation, etc.) you will report as 4, 7, 4 and income as NA.

First published on BankersOnline.com 3/18/13

First published on 03/18/2013

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