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Two HMDA Questions

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Should we put the HMDA worksheet in the loan file? Why don't we need to do a rate spread on commercial loans, but we still need to put the GMI in the file?

Why not put the HMDA worksheet in the loan file? This will expedite the audit/exam process. Commercial loans don't have an APR; therefore, no rate spread is reported. If you collect GMI, you should have supporting documentation.

First published on 5/10/10

First published on 05/10/2010

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Filed under lending as: 

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