You only report information for the first two borrowers. Which borrowers you report is up to you; however, I would go with the order they are listed on the note. For example if the note lists the borrowers as LLC #1, LLC #2 and then John Doe, you would report the GMI using the codes for “n/a” for both the borrower and co-borrower on the HMDA-LAR. You would still collect GMI for John Doe; you just won’t report it on the HMDA-LAR.
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