HELP!
For as long as my Bank has existed, we have been very careful about the collateral taken for a loan to ensure that we did not have to commence HMDA reporting. Therefore, we did not make any loans where the collateral included a single family dwelling/residence. We either turned the loan down or had the Borrower carve off the parcel prior to closing the loan.
We did just that with a golf course loan several years ago. A house in which the course maintenance manager lived was not taken as collateral. That golf course is now OREO. The maintenance manager still lives in the house and the Bank does not own the house. From a strategy standpoint we are looking at the pros/cons of acquiring the house from the former borrower so that we can sell it along with the course to a buyer.

Since we no longer have a mortgage, can we infer it would be acceptable to own the house and remain exempt from HMDA reporting?


Thanks for your guidence

Are you making a loan for the purchase of a dwelling? Refinance of a dwelling secured loan - meaning the satisfaction and replacement of a dwelling secured loan with another to the same borrower? Or to make improvements to a dwelling or the property on which it sits?
If no, then no.

Hi Rizzo,
I believe to make improvements to the property on which it sits would be a correct assumption. The Loan Committeee thinks by buying the house, it would make the golf course a better buy or improve the overall value of the OREO property.
Therefore, if this is true, it would trigger HMDA reporting?
Thanks