HMDA Reporting, Commercial Loans, and GMI

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Question:

For HMDA reporting: If I have a commercial loan/business purpose where the applicant is a natural person, should I answer N/A for monitoring information, or am I obligated to complete the motioring info in the form based on observation. (The commercial loan application does not provide for collecting the government monitoring.

Answer:

You should only collect government monitoring information (GMI) on a commercial purpose loan, if a natural person will become personally liable. If the person signs the note only in the capacity of an officer, you should not collect GMI. If the person is personally liable you do collect GMI.

First published on BankersOnline.com 8/05/02