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New Gov Monitoring Info for Each Loan Renewal?

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Question: 
We are a HMDA bank. Do we need to collect new government monitoring information at each loan renewal if the borrower(s) have not changed?
Answer: 

Renewals are not reportable. If you are referring to refinances then yes. There is no allowance to use previous collected information in Reg C as there is in Reg B.

First published on BankersOnline.com 7/11/11

First published on 07/11/2011

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