10/16/2006
For HMDA reportable loans, should we be collecting and reporting Government Monitoring Information for Loan Guarantors?
10/02/2006
A home loan application was completed on a consumer loan refinance on their dwelling and Credit Life Insurance was financed on the loan. Is the government monitoring information required or prohibited on the home loan application? (Is a refinance with cash out (ie credit life insurance) or cash out for personal use, medical, etc., subject to government monitoring information?)
08/14/2006
We are not a HMDA reporting bank, however, I was just told that we still have to collect monitoring information on purchases and refinances of purchases. Is this true, if so where can I find this in the Reg?
08/14/2006
I know there is a violation for not reporting loans that should be for HMDA purposes. It was brought up at one of our meetings that it is better to over-report loans for HMDA purposes rather than to under-report. Is that true, or will we be in violation for over-reporting as well? Any clarification would be greatly appreciated.
04/03/2006
In compiling my 2005 HMDA data, I have a lender who collected government monitoring information on temporary loans (construction or bridge). These are not HMDA reportable, but can he still collect the GM under Reg B, or will this be a violation?
02/20/2006
I have a customer that currently has a real estate loan and an equipment loan with the bank. He wants to combine the loans and get funds to start a new business. Do I give him an application with monitoring information, or without monitoring information?
02/13/2006
HMDA - We have a business loan to three borrowers to purchase a 1-4 family dwelling for investment purposes. One of the borrowers is a formal business entity, and the other two are the two individuals that own the business. The business entity is the primary borrower, but the individuals also sign on the note individually. We are not clear regarding the issue of reporting monitoring information in such a case -- we have had much discussion, and have done much research about this and can't come up with a consensus. In situations where you have a business entity borrowing, AND you also have individuals signing individually on the note, should you report monitoring information on one, or both of the individuals since they are individually signed on the note also? In such a situation would we show the monitoring fields on the applicant, i.e. the business entity as NA, and show monitoring information on one of the individuals under the co-applicant fields? Any guidance you could provide would be greatly appreciated.
11/01/2004
The final lap of the new 2004 HMDA reporting is now being run.
05/17/2004
We have some confusion regarding completing the Government Monitoring Information on the new Uniform Residential Loan Application. Are we required to complete Ethnicity, Race, and Sex (all three)? If we are, and we have a customer who checks Hispanic or Latino, does not check race, and in our observation believe they are 100% Hispanic, what do we check for race? </strong>
04/19/2004
I'm in the process of completing an audit of the Fair Housing Act for a national bank. The OCC requires that "each bank shall attempt to obtain all of the information below." It then goes on to require a considerable amount of information in excess of the traditional government monitoring information (race, ethnicity, sex, marital status, and age). Is all of this information required to be on the application? Will the information (such as amount requested, interest rate requested, # of months to maturity, and proposed monthly payment) being in the loan file on some other document suffice? Also, does the fact that the application is partially completed suffice for compliance with the regulation for "attempting to obtain" the information?