HMDA & Monitoring Data

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Question:

In short, we are now under HMDA. Until now, there were instances when getting monitoring info would get us into trouble. Can we now get monitoring info on every "1003" application we take without fear of violations.

Answer:

Some banks tried to simplify the application process and use just one application for all loans. In this case a 1003 doesn't work. Both Regs. B and C apply to monitoring information and when it should be collected. Review 203.4(b) and 202.13(a).

First published on BankersOnline.com 5/7/01