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Demographic Addendum Section on URLA

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If an applicant completed the Demographic Addendum section on the new URLA and the loan is not HMDA reportable because it is a construction loan, can the GMI be crossed out, or how should this be corrected?

13(b)(6) in Reg B allows that if you inadvertently collect monitoring information it would not be considered a violation so there is no need to doctor your file. What is needed is a review of why it was collected and what steps can be taken to avoid it happening again.

I have heard of some examiners who said that if they saw it multiple times it would be more of a pattern or practice and less of an inadvertent error. Some banks would screen applicants and black out the GMI section so that it could not be completed or to provide very explicit instructions but even then, those could be considered insufficient if the data was continually provided.

First published on 12/12/2021

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