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GMI On Unsecured Consumer Loans: Reg B

12/04/2016

My question is that our compliance department is asking operations to gather GMI on all unsecured consumer loans that are currently on our books. The purpose is to run comparisons for fair lending. I have researched this and find that it is not allowable under Reg B, however the argument is that these are already our loans and we are not asking the borrower for it up front to make a lending decision. I would appreciate your opinion.

Loan Application with GMI Gender Mistake

11/01/2015

We have a loan application that was taken face to face. The LO marked the GMI sex box as female when the borrower was male. Obvious mistake. The loan closed without being corrected. We have had contradicting information from auditors and regulators that say that we report exactly what was put on the application and that we should report the correct sex as we know it was an error.... which way do we go here?

Govt Monitoring Form No Longer Required? HMDA

10/04/2015

Our loan software provider has recently deleted the Government Monitoring Form from the list of required documents on loans subject to HMDA. Is this completed form no longer required on HMDA loans?.

Is a Trust a Person?

09/23/2013

Would a trust be considered a legal entity or natural person when it comes to Truth in Lending, RESPA, and HMDA disclosures?

Correcting Gov Monitoring Info on Broker App

04/30/2012

On a Broker application, is the investor allowed to correct the Government Monitoring Information if what is marked is not consistent with the picture ID in the file?

Government Monitoring Information Requirements

02/13/2012

I have a question regarding the government monitoring information requirements under Section 202.13 of Reg B</a>. We are not a HMDA reporting bank. If we were to do a home equity loan for a customer and then that same customer requested additional money on that home equity (or a refinance), would you then at that point be required to collect government monitoring information?

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Handling Reg E "Dated" Claims

12/29/2024

In July, a customer submitted a Reg E dispute for debit card transactions which happened in March, April, and May. The first statement was in April. The customer still has his card. The dispute team processed the claim, eventually finalizing it by crediting the customer for the first statement plus 60 and denying the remainder. Earlier this month (September), the customer filed another claim for the same merchants but for an earlier period, December-February. Do you agree that this must be treated as a separate claim because the first one was already made final? If the second claim came in before the first was closed I am assuming we can combine the two since the same merchants are being disputed.

HMDA Reportable Transaction Exclusions

12/22/2024

I actually referenced these as well which is what I used to support my interpretation; however, the other interpretation I heard the reason they said they got to that was following the citations along with the HMDA reportable transaction exclusions. So 12 CFR § 1002.104(b)(2) then if you go to the citation referenced there 12 CFR 1003.2(e) then go to the 1003.3 (C) referenced there. So looking at those exclusions it doesn’t mention anything in regards to if your bank is in an MSA or not but #11 references FI that have fewer than 25 loans. Hence, that being their reasoning that the only way non HMDA banks would exclude HMDA transactions was if they were non-HMDA due to loan volume. I’m not disagreeing with your answer because that was our interpretation as well but when following the citations that they used to come up with their interpretation and can see why they would maybe think that.”

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