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Two HMDA Questions

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Question: 
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?
Answer: 

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 BankersOnline.com 5/10/10

First published on 05/10/2010

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