Visual Observation to Complete Info on LAR

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Question:

I have a real estate loan that the customer checked on the GMI information that they do not wish to furnish this information. We are HMDA reportable. Do I use visual observation to complete the information on the LAR?

Answer:

Depends if the application was taken face to face or if you met with the applicants anytime during the application process if the application was taken by phone, mail or Internet.

If the application was taken face to face you must report based on visual observation and surname if the applicant declined to provide the information.

You can find additional guidance in the GIR.

First published on BankersOnline.com 12/5/11