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#1381873 - 04/27/10 02:00 PM Loan Purpose Question
Still Smiling Offline
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I am looking for where it states that you cannot use the loan purpose "personal".

I realize that this would not be acceptable practice for real estate secure loans, but is there really a regulatory restriction for other loans? Would greatly appreciate help.
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Lending Compliance
#1381875 - 04/27/10 02:04 PM Re: Loan Purpose Question Still Smiling
Truffle Royale Offline

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Use the loan purpose in what way? If you're talking HMDA, you can do a real estate secured loan for personal reasons such as financing a vacation or an education. It's just not HMDA reportable unless you're paying off another mortgage and taking cash out for personal reasons. That would be a refi.

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#1381878 - 04/27/10 02:13 PM Re: Loan Purpose Question Truffle Royale
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Right, I am trying to find out if there is a prohibitation for stating that the loan purpose is for "personal reasons" on a non real estate secured loan, and if so where do I find this discussed in regulation.
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#1381880 - 04/27/10 02:14 PM Re: Loan Purpose Question Still Smiling
Skittles Online
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The Bank Secrecy Act requires a specific purpose on loans in excess of $10,000 not secured by real estate.
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#1381889 - 04/27/10 02:22 PM Re: Loan Purpose Question Skittles
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Thanks Duchess, I thought there was some reason why this would not be permitted just couldn't remember why.
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#1381890 - 04/27/10 02:25 PM Re: Loan Purpose Question Still Smiling
Skittles Online
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Additionally - a lot of loan policies in banks state something about the loan purpose being legal. How would anyone now if it's legal or not without a specific purpose. Just makes good sense - although I now working with and being married to a lender that 'sense' doesn't always come into play. Ha!
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#1381909 - 04/27/10 02:31 PM Re: Loan Purpose Question Skittles
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Tis so true! I was concerned about this because of REG Z education loan requirements and of course a loan amount is not mentioned in that guidance.
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#1382026 - 04/27/10 03:42 PM Re: Loan Purpose Question Still Smiling
swiggles Offline
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Also, without a specific loan purpose, if you have more than one borrower, how would you know if one of them actually meets the definition of a cosigner?....to which you must provide a cosigner notice under Reg AA. If a person receives no goods or services from the loan, that person is a co-signer regardless of the name you apply to the person on the loan documents.
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#1382143 - 04/27/10 05:10 PM Re: Loan Purpose Question swiggles
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Thanks guys...I appreciate the help.
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