Reg B and GMI on Real Estate Loan

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Question:

We are not a HMDA reportable institution. Our bank was under FDIC receivorship. We were a State Chartered Bank, and we are now a National Bank. Since we are not required to report HMDA at this time, are we allowed to gather GMI on the initial 1003 for a real estate loan, or is this a violation of Reg B?

Answer:

If the loan is for the purchase or refinancing of the consumer's primary dwelling and will be secured by that dwelling, then Reg B requires the collection of GMI. See 202.13 and its Commentary.

First published on BankersOnline.com 1/03/11