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Q: We understand the Government Monitoring Information ("GMI") answer options have changed with the new HMDA rules, but can you explain our reporting obligations?
The HMDA Rule provides a transition provision that allows a financial institution to report the applicant's ethnicity, race, and sex under the new HMDA rule requirements in effect at the time that the financial institution collects the information, not when the financial institution takes final action on the application. Thus, if a financial institution receives an application prior to January 1, 2018, but final action is taken on or after January 1, 2018, the financial institution complies with the new rules if it collects the information in accordance with the requirements in effect at the time the information was collected.
Many financial institutions have begun to require the collection of the new GMI information and adopted the use of the Demographic Information Addendum issued by Fannie Mae. If you intend to use this document, the Agencies advised that you should cross out or delete Section X of the Uniform Residential Loan Application ("URLA") and replace it with the Addendum. The Addendum may be found at: https://www.fanniemae.com/content/guide_form/urla-demographic-addendum.pdf
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