Collecting Government Monitoring Information

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Question:

My question is in regards to Regulation B Monitoring Infomation. We are a non HMDA reporting bank. We have received mixed information concerning the collection of the monitoring information on telephone, mail and internet applications. Does the creditor need to complete the monitoring information on telephone, mail or internet applications to purchase or refinance the applicant's personal residence?

Answer:

Reg. B's Official Staff Interpretations
202.13(b)

3. Telephone, mail applications.
i. A creditor that accepts an application by telephone or mail must request the monitoring information.
ii. A creditor that accepts an application by mail need not make a special request for the monitoring information if the applicant has failed to provide it on the application form returned to the creditor.
iii. If it is not evident on the face of an application that it was received by mail, telephone, or via an electronic medium, the creditor should indicate on the form or other application record how the application was received.

First published on BankersOnline.com 11/15/04