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Is it a violation to collect GMI on loans that are not subject to HMDA or Reg B collection such as a loan to purchase an empty lot or land? Are we permitted to make a procedural decision that we will collect GMI on all loans at application?
Section 1002.5(b) of Regulation B states, “A creditor shall not inquire about the race, color, religion, national origin, or sex of an applicant or any other person in connection with a credit transaction, except as provided in paragraphs (b)(1) and (b)(2) of this section.” The exceptions allow collection of monitoring information as required by Section 1002.13 or under a substitute monitoring system, such as Regulation C.
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