We are a non-HMDA bank. According to Reg B we are to collect GMI for loans to purchase or refinance a dwelling occupied or to be occupied by the applicant as their principal residence and is secured by the dwelling. If a borrower is doing a refinance with their primary residence as collateral but the loan that is being refinanced is unsecured do we collect the GMI? What if the unsecured loan was for the initial purchase of the home? What if the unsecured debt was for personal reasons NOT to purchase the home? I wanted to confirm if we collect it if either scenario comes up.