Why, oh why, does the collection of GMI have to be so difficult?

It seems like one is doomed whether they collect the information or not! I understand the intent of collecting the information, but why print the darn section on the URLA, for the applicant to fill out willy nilly?

I'm dealing with an over-collection issue, often because the customer is generous enough to complete the section while completing the app -- they don't know we aren't supposed to have it on their lovely little home improvement or debt consolidation request!

The rest of the time, it seems like some lenders are so afraid of missing something, they just do everything under the sun. While it is fine to have an unneccessary preliminary disclosure, they are getting burned on GMI.

GRRRRRRRR!!

Thanks for letting me vent..... back to my loan review.....

GMI burned us in our last audit also. Our issue was collecting GMI on what turned out to be just a lot vs. a construction loan.

At one time there was a Reg. B proposal for us to collect GMI on every consumer loan regardless of purpose. This would have made it easier for lenders, but.... thankfully it was not made part of the requirement (it would have brought us one step closer to credit allocation).

So, is GMI required on construction loans? I thought not?

But just a construction loan, whether to build or purchase a mobile home, that is temporary 6-9 months, is NOT subject to GMI, correct?

I pulled up Reg B on fdic.com & read 202.13. I don't see where it discusses "temporary financing"?

Regulation B Official Staff Interpretations.

Thank you!