If an LLC obtains a HMDA loan without a co-applicant, but there are 2 guarantors that are individuals, would one of the guarantors be reported on the LAR for the co-applicant GMI, or would we report 5-8-5 for the co-applicant since technically there really wasn’t a co-applicant?
If we should not report GMI for the guarantors on the LAR and we requested GMI on the application for them, is that an actual violation, or do we only need to ensure our procedures are corrected and employees properly trained? How should we document the loan if at all?
You collect GMI on the applicant/borrower. In your case, the LLC is the applicant and can’t provide GMI, so you input NA. A guarantor is not an applicant, so you should not collect GMI. I would train and move on.