Compliance Alliance Q&A 7-23-18
If we are not a HMDA bank, do we still need to collect Government Monitoring Information on mortgage loans?
Yes, but only for a home purchase or refinance of a home purchase loan secured by a dwelling that is or will be used by the borrow as a principal dwelling.
Regulation B provides the following:
(a) Information to be requested. (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 as part of the application the following information regarding the applicant(s): 12 CFR 1002.13(a): https://www.consumerfinance.gov/eregulations/1002-13/2013-22752_20140118#1002-13
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