Skip to content
BOL Conferences
Thread Options
#1890000 - 01/24/14 03:53 PM Home improvement loans ,Non-dwelling secured HMDA
Mark Burns Offline
New Poster
Joined: Jan 2014
Posts: 9
I recently attended a webinar by David Dickinson on HMDA. According to Him a home improvement loan that is non-dwelling secured must also be classified by the lender as Home improvement to be HMDA reportable. Question? What are the other banks doing on this?
If a person borrows $2000 unsecured to repair his Air conditioner are other banks classifing this as home improvement and reporting? Are repairs automatically HMDA?
Like I said how are the other banks choosing to report such consumer loans?

Return to Top
HMDA

   
HMDA Academy
#1890004 - 01/24/14 03:58 PM Re: Home improvement loans ,Non-dwelling secured HMDA Mark Burns
raitchjay Online
Power Poster
Joined: Oct 2009
Posts: 9,086
OK
We don't internally classify non-dwelling secured HI loans as HI, therefore we don't report them. My advice: i'd attack this problem the opposite way from what it sounds like you're doing. First, determine internally whether or not you classify such loans as HI (in other words, if you wanted to pull a list of all your home improvement loans, through your core system, etc.....could you fairly easily do so? Or do you group or color code such paper files in a way that you could pull out the HI ones easily?) If the answer is yes, then you have to report them. If the answer is no: i definitely wouldn't go out of my way to start classifying them so that i would have to report. Hope that helps.
_________________________
I'm fixin' to fix that.

Return to Top
#1890011 - 01/24/14 04:11 PM Re: Home improvement loans ,Non-dwelling secured HMDA Mark Burns
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,226
Galveston, TX
And if you are doing it - stop. If you don't have to report them, you can't mess up the reporting.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1890038 - 01/24/14 04:45 PM Re: Home improvement loans ,Non-dwelling secured HMDA Mark Burns
swiggles Offline
Power Poster
swiggles
Joined: Aug 2001
Posts: 7,351
Ditto with Randy. And if you're not currently reporting home improvement loans that are not secured by a dwelling, attempting to start that unnecessary process will require re-training lenders and others, because lenders are probably NOT accustomed to gathering GMI for those types of loans. What's more, staff that DO take applications for those types of loans may not even know what GMI is or that it involves providing a disclosure to the applicant about why you're asking questions about race, ethnicity and sex.
_________________________
The more you sweat in training, the less you bleed in battle.......

Return to Top
#1890047 - 01/24/14 04:51 PM Re: Home improvement loans ,Non-dwelling secured HMDA Mark Burns
Mark Burns Offline
New Poster
Joined: Jan 2014
Posts: 9
So far, the recomendation is for non-dwelling consumer loans are not to be classified as home improvements so dont report.

Return to Top
#1890061 - 01/24/14 05:07 PM Re: Home improvement loans ,Non-dwelling secured HMDA Mark Burns
Mark Burns Offline
New Poster
Joined: Jan 2014
Posts: 9
thanks

Return to Top
#1890191 - 01/24/14 07:15 PM Re: Home improvement loans ,Non-dwelling secured HMDA Mark Burns
swiggles Offline
Power Poster
swiggles
Joined: Aug 2001
Posts: 7,351
Originally Posted By: Mark Burns
So far, the recomendation is for non-dwelling consumer loans are not to be classified as home improvements so dont report.
It's totally up to management at your bank as to whether you report these loans or not. Most banks don't report for reasons stated above. I have heard, though, some bank's want the added support of those loans on the LAR for whatever reason......not really sure what that reason might be. But reporting is totally optional. Just remember, if you "classify" you MUST report. If you don't want to report, just make sure there is no way to pull a list of these from your data base or hard copy files. Pay attention to purpose codes, if you use those. If you use a code for "home improvements" then your loans are classified and you must report the loans.
_________________________
The more you sweat in training, the less you bleed in battle.......

Return to Top
#1891388 - 01/28/14 08:53 PM Re: Home improvement loans ,Non-dwelling secured HMDA Mark Burns
80's Lady Offline
Gold Star
Joined: Apr 2007
Posts: 295
Mark - we will be a new reporter next year (so excited - NOT!), and I had a similar question. We have decided not to classify/report the HI loans not secured by a dwelling. See my previous post:

http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1887270#Post1887270

I am already so grateful for this forum!
Last edited by 80's Lady; 01/28/14 08:55 PM. Reason: clarification
_________________________
I use to think I was a smart cookie before I started working in Compliance. Now, I have mastered the art of the blank stare!

Return to Top

Moderator:  SMQ, CRCM