Answer:
Answer by Ken Golliher: I will readily defer to anyone with specific knowledge of this particular from. However, I doubt that it will be modified to include the CIP information. If a bank relies on its applications as the method for retaining CIP information, it would automatically extend their retention period. That is something most banks would want to avoid for a vairety of reasons.
Answer:
Answer by Lucy Griffin: The uniform residential application form (1003) is being changed to conform to the changes in Regulation B but not anything in CIP. Thus, the CIP will have to be built around underwriting issues, such as careful study of the credit bureau report to determine whether the applicant is who he or she claims to be and analysis of the appraisal to be sure that the property is appropriate for the applicant.
The collection of monitoring data (race, ethnicity, and gender) is still mandatory for HMDAreportable loans and this will be on the 1003. However, collection of the same information is prohibited in any other credit application. So CIP must do something besides make a copy of the driver's license a Regulation B nono.
First published on BankersOnline.com 10/6/03
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