[cbsimpson]

Hi. My question is in regards to collecting demographic information for joint credit. Suppose I have a HMDA loan that is a business entity with 4 applicants applying for joint credit. 2 questions:

1) Do all 4 applicants complete an application?

2) If not, do all 4 applicants complete a demographic addendum?

Topic

[kowsley]

First you have to determine who the applicant is. If the applicant is the business (non-natural person) you wouldn’t collect demographic information; whether an application is taken is dictated by your financial institutions procedures.

If the applicants are the individuals but the transaction is a business purpose transaction it is typically an exempt transaction for HMDA unless it is for home purchase, home improvement, or refinance. In this case, you can take one application with multiple applicants and if you are HMDA covered you would collect demographic information for all four individuals.

[cbsimpson]

Thank you very much! Where can I find the information on this topic? I would like to print it for future reference because I will undoubtedly forget. Lol. Again, thank you very much!

[kowsley]

Unfortunately, the information is spread throughout Regulation C – HMDA. You can retrieve the definition for application under section 1003.2(b) and for covered loan under section 1003.2(e). As far as whether you should collect monitoring information, you can retrieve that from Appendix B of Regulation C.

[Author]

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