[lisa.cuevas]

It would be covered under the new rule, but not under the current rule.
So if we collect GMI and it becomes actionable in 2017, are we ok to do so even if it will not be reported under the current purpose test? We do not currently report HELOCs, so if we collected GMI information on it, would we be ok if we collected the info even if it is actioned in 2017.

This will help determine if we can hit the switch prior to 01/01/2018.

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