The fact that Government Monitoring Information is not required on all Residential Mortgage Loan Transactions unless they are HMDA reportable sets banks up to fail.
This part of REG C needs to be carefully re-considered. HMDA reporting is very complicated and time-consuming, and whether or not GMI has been collected further complicates the issue.
Comment on CFPB-2011-0020-0001
This is comment on Rule
Home Mortgage Disclosure (Regulation C)
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