Q: State Bank has a customer who is getting a home equity loan for home improvement and debt consolidation for credit cards. Is the bank required to gather GMI/Demographic Information and is this HMDA reportable?
A: It would be HMDA reportable if the purpose of the loan is for improvement of a dwelling and is also secured by a dwelling. So, assuming that is the case, and it is reportable, then yes, GMI/demographic information would be collected and reported as applicable.
Reference: https://www.consumerfinance.gov/policy-compliance/rulemaking/regulations/1003/2/#i
Compliance Alliance offers a comprehensive suite of compliance management solutions. To learn how to put them to work for your bank, call (888) 353-3933 or email info@compliancealliance.com and ask for our Membership Team. For timely compliance updates and resources, subscribe to BankersAlliance’s email newsletters.
Not a member? Learn more about membership with Compliance Alliance by attending one of our live demos:
