Demographics

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Question:

A loan was originated that began with an individual borrower but closed in the name of an entity. We initially collected GMI on the individual and reported it as such. Is this acceptable for HMDA?

Answer:

Do not report the demographic data that was initially collected unless the individual remains as a co-borrower with the entity. Document the file as to how and why the GMI was collected. It was appropriate at the time it was collected and is therefore not a violation.

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