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GMI on a PQ App???

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  • #2499
    dmurray
    Participant

    We want to go “Online” with our mortgage “Pre-qual application”. (Basically a short form mortgage application) I’m a little concerned with this, as it asks a lot of specific information. There are 5 req’d pieces of information to be considered an application for RESPA purposes, collected on this appliation. The missing piece is the property address and if you’re looking at a Refinance request, you’ve got all the information necessary for RESPA. We want this to be a pre-qual application though, not an application that collects enough information to start any sort of RESPA timelines.

    My problem is, Government Monitoring is to be collected at the time of the application. There are times when we don’t know if the loan will be HMDA reportable because, it could end up being a Home Equity loan. (Where we’re not replacing a lien on a property because it’s already been paid off.) So should we add this information to the application due to the collection of all the RESPA info? Or not? It really seems like this would be a violation either way.

    Also this application does not include a “Notice of Joint Intent” all it asks is if there is going to be another borrower. If so,… please complete their information. etc etc etc.

    I know that JVI is to be collected at the time of application, where in the regs does it mention this?? I have combed all the way through Reg. B. Is there something I’m missing?? I’ve already explained for the customer to be able to hit “Submit” on the online application that they should have to complete this. I just don’t have any firm ground to stand on in this case.

    All help is appreciated.
    Thanks

    #2937
    JGo9
    Participant

    Here is the citation for joint intent: Supplement I to 12 CFR 202, Staff Commentary, comment no. 3 to ยง202.7(d)(1)

    You need to be sure to follow all of the required regs, sounds like you may need to have two different applications.

    #2954
    dmurray
    Participant

    Thanks, that was my thinking too.

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