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HMDA Reporting on Commercial Loans
by David Dickinson, BOL Guru
Guru Bios
Question: Are commercial loans secured with personal guarantees HMDA reportable?
Answer: Commercial loans may certainly be subject to HMDA, but they must be a "home purchase loan" and secured by a dwelling, a home improvement loan or a refinancing where both the old and new loans are secured by a dwelling. Personal guarantees have nothing to do with HMDA. If you are wondering if guarantees that are collateralized by a dwelling make a loan subject to HMDA, the answer is no.
First published on BankersOnline.com 2/05/07
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