Not Subject to HMDA Reporting - Collect GMI?

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Question:

If part of the proceeds on a home equity loan are being used for home improvement, are we required to collect government monitoring information if we are not subject to HMDA reporting?

Answer:

You are always subject to the GMI collection requirements of Reg B's 202.13 and its Commentary. You should become familiar with that section. A home improvement loan request is not subject to GMI collection under Reg B.

First published on BankersOnline.com 3/23/09