Reply To: Reg B GMI


For purposes of Regulation B, monitoring information must be collected if the loan is a purchase or a refinance. If the property transfers before closing, the loan is not a purchase. A refinance must involve the sake borrower. Apparently the existing debt is in the grandmother’s name; the new loan would be in the granddaughter’s name. Different borrowers, therefore not a refinance. If not purchase or refinance then monitoring information is not required for Regulation B.