If a borrower chooses not to provide the Government Monitoring Information and the application was taken face-to-face, what must the MLO do?

If a borrower chooses not to provide the Government Monitoring Information and the application was taken face-to-face, what must the MLO do?

• A. Write the words 'Visual Observation' above the declination to answer and guess
• B. Leave the declination blank
• C. Ask the borrower to provide the information later
• D. Delete the Government Monitoring Information section

Answer: (A)

When a borrower declines to provide Government Monitoring Information in a face-to-face loan application, the file should clearly show that decision. The best approach is to annotate the declination with the phrase “Visual Observation” so the file reflects that the information was not provided by the applicant and that the originator is documenting the circumstance. This keeps a complete, auditable record for regulatory monitoring under ECOA without leaving the GM section empty or deleting it. It also signals that the borrower’s choice was respected rather than forcing data collection later or guessing. Leaving the declination blank, asking for the information later, or deleting the GM Information section would fail to properly document the applicant’s choice and the file’s compliance status.

When a borrower declines to provide Government Monitoring Information in a face-to-face loan application, the file should clearly show that decision. The best approach is to annotate the declination with the phrase “Visual Observation” so the file reflects that the information was not provided by the applicant and that the originator is documenting the circumstance. This keeps a complete, auditable record for regulatory monitoring under ECOA without leaving the GM section empty or deleting it. It also signals that the borrower’s choice was respected rather than forcing data collection later or guessing. Leaving the declination blank, asking for the information later, or deleting the GM Information section would fail to properly document the applicant’s choice and the file’s compliance status.