Reply To: HMDA Application- When to collect monitoring?


From the information you’ve given, it sound as if you received the application over the phone, so this is when you should request the GMI. Take a look at Reg C, Appendix B (linked below) to ensure your procedures for requesting GMI over the phone are accurate. Also, remember to mark how the application was received (phone, mail, FTF…). Below are the definition of application from Regs B and C.

Reg B: 1002.2(f): Application means an oral or written request for an extension of credit that is made in accordance with procedures used by a creditor for the type of credit requested. The term application does not include the use of an account or line of credit to obtain an amount of credit that is within a previously established credit limit. A completed application means an application in connection with which a creditor has received all the information that the creditor regularly obtains and considers in evaluating applications for the amount and type of credit requested (including, but not limited to, credit reports, any additional information requested from the applicant, and any approvals or reports by governmental agencies or other persons that are necessary to guarantee, insure, or provide security for the credit or collateral). The creditor shall exercise reasonable diligence in obtaining such information.
1002.13(a)(1): A creditor that receives an application for credit primarily for the purchase or refinancing of a dwelling occupied or to be occupied by the applicant as a principal residence, where the extension of credit will be secured by the dwelling, shall request…
Reg C:
1003.2(1): Application.—(1) In general. Application means an oral or written request for a home purchase loan, a home improvement loan, or a refinancing that is made in accordance with procedures used by a financial institution for the type of credit requested.