Collecting Government Monitoring Information (GMI) Under Regulation B. On July 1, 2020, the HMDA threshold for closed-end loans will increase from the 25 to 100. … It means you will
no
longer be subject to HMDA data collection and reporting for closed-end loans.
When should you not collect government monitoring information?
Regulation B requires that the lender obtain the government monitoring information from all applicants for
a loan
to purchase or refinance a principal dwelling (other than temporary financings).
What information does the government monitoring information section ask for?
The creditor shall inform the applicant(s) that the
information regarding ethnicity, race, sex, marital status, and age
is being requested by the Federal Government for the purpose of monitoring compliance with Federal statutes that prohibit creditors from discriminating against applicants on those bases.
Can government monitoring information be used in a credit decision?
Government monitoring information may be used in
a credit decision
. Disregarding the income of a working spouse on a joint application is considered to be a sound risk management practice. If a credit application is denied after the application was withdrawn, a notification must still be made.
What is included in HMDA monitoring information?
HMDA requires that a creditor collect
information on all applications for home purchase loans, home improvement loans, and refinancings
. The information that HMDA collects regarding an applicant differs slightly from Reg. B. HMDA requires the collection of the applicant’s ethnicity, race, and sex.
What is Reg Z in banking?
Regulation Z
prohibits certain practices relating to payments made to compensate mortgage brokers and other loan originators
. The goal of the amendments is to protect consumers in the mortgage market from unfair practices involving compensation paid to loan originators.
What does the Equal credit Opportunity Act prevent?
This Act (Title VII of the Consumer Credit Protection Act)
prohibits discrimination on the basis of race, color, religion, national origin, sex, marital status, age, receipt of public assistance
, or good faith exercise of any rights under the Consumer Credit Protection Act.
What is a denial of credit called?
An adverse action notice
is a written, electronic, or verbal disclosure creditors must issue to consumers after their credit-based application (a credit card or loan, for example) is denied or they face another negative credit-related action. The purpose of the notice is to communicate the reason for the denial.
When should loan Estimate be delivered?
A Loan Estimate is a three-page form that you receive after applying for a mortgage. The Loan Estimate tells you important details about the loan you have requested. The lender must provide you a Loan Estimate
within three business days of receiving your application
.
What is a HMDA LAR?
FR HMDA-LAR The
Home Mortgage Disclosure Act/Loan Application Register
. Description: This report takes the form of a register of mortgage and home improvement loan applications and their disposition during a calendar year. Home Mortgage.
What loans does Reg B apply to?
Regulation B covers the actions of a creditor before, during, and after a credit transaction. The CFPB lists credit transactions and aspects of credit transactions to include
consumer credit, business credit, mortgage, and open-end credit
.
Is HMDA under ECOA?
Currently, the ECOA restricts lenders’ ability to ask consumers about race, religion, nationality or sex except as it relates to the required collection of such information for some mortgage applications, subject to certain exceptions, including
Home Mortgage Disclosure Act
(HMDA) reporting.
What regulation is ECOA?
The Equal Credit Opportunity Act (ECOA), which is implemented by
Regulation B
, applies to all creditors. When originally enacted, ECOA gave the Federal Reserve Board responsibility for prescribing the implementing regulation.
What HMDA data is available about loans?
HMDA reporting allows
regulators to analyze information on mortgage loans and mortgage lending trends
in a number of categories, such as the number of pre-approvals made, the number of mortgages granted, loan amounts, and the purposes of individual loans.
What is ECOA?
The
Equal Credit Opportunity Act
(ECOA), which is implemented by Regulation B, applies to all creditors. When originally enacted, ECOA gave the Federal Reserve Board responsibility for prescribing the implementing regulation.
