GMI reporting for HMDA purposes

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Question:

Currently our policy is when we have a face to face application and only the applicant is in front of the loan officer, he/she marks the face to face box and the 3 boxes,( ethnicity, rate and sex) for the person in front of him/her. It is then our policy to contact the other applicant by phone and ask the GMI questions of the person that was not in front of the loan officer. Next the loan officer is to complete the GMI for that applicant (indicating he/she does not wish to furnish the information OR completing the 3 boxes) but write on the signature line that the information was taken by phone. Is that correct? Or on these face to face applications should we be completing the GMI information for the applicant that is not in front of the loan officer based on observations such as their last name or ask the applicant that is in front of the loan officer?

Answer:

First, the loan officer must give the person in a face to face the opportunity to provide the information or decline to. If they (the applicant) decline only then does the loan officer mark the information based on visual observation.

The applicant present in the interview may provide the GMI for the non present applicant. Your process would be acceptable but creates an unnecessary step.

First published on BankersOnline.com 4/11/11