Reinstated Applications: Practical Application of the HMDA Commentary
Lucy Griffin, BOL Guru Guru Bio
QUESTION: FRB hotline has indicated that only applications that are resubmitted unchanged can be considered as reinstated - any changes would equate to a new 2nd application. This seems impossible to practice - any change in loan amount, counteroffer renegotiations, etc. Ideas?
ANSWER: There are lots of things about HMDA that aren't very practical. this is a good time to let the Federal Reserve Board know because they have HMDA issues out for comment. A useful comment letter would include a description (nothing very fancy, just practical) of how a resubmitted application occurs. That helps the regulators draw a more livable distinction.
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