Phone Apps & Collecting Government Monitoring Data

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Question:

I want to verify a procedure on collection of government monitoring information on residential real estate applications. If an application is a telephone application at what point are you required to have the government monitoring data collected either through the customer completing or through visual observation? We have an associate questioning whether the data has to be collected at all on a telephone application. We have been collecting it on the final application signed at closing on telephone applications. What is correct?

Answer:

The GMI is to be collected at the time the application is taken by telephone. The interviewer must read the disclosure to the applicant(s) and request the information. If the applicant chooses they do not wish to furnish the information that is what the interviewer marks. If you do not meet with the applicants face to face at anytime during the application process you have no further obligation to collect the GMI. Meeting with the applicants at closing is after the application process, therefore you would not be required to collect GMI at that time, but you are allowed to do so if you wish. See Application Data on page D-13 of "A Guide To HMDA Reporting Getting It Right!"

First published on BankersOnline.com 9/29/08