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#191379 - 05/18/04 05:52 PM HMDA and Assumptions
Suzie Offline
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Suzie
Joined: Apr 2002
Posts: 662
Far North
Good day all. I need some help and clarification on reporting assumptions on the HMDA LAR.

It has always been my understanding that all assumptions are reported. Ran across an internal memo however that suggests that a simple assumption, one not requiring a credit check, etc. is not a HMDA reportable loan.

I have never heard of this before!! For HMDA reporting purposes, does anyone else treat simple assumptions (no underwriting) differently than qualified assumptions (standard loan underwriting)?
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Lending Compliance
#191380 - 05/18/04 06:09 PM Re: HMDA and Assumptions
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
Look to page D-2 of the GIR.

We don't do assumptions, but my understanding is if the lender agrees to the assumption with a written agreement the assumption is reportable as a purchase. Does not matter if it went through underwriting or not.

Although rare, I would say there may still be notes out there that allows an assumption between the borrower and the person assuming the debt without lender intervention. These would not be reportable because there is no written agreement between the bank and the person assuming the debt.
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#191381 - 05/18/04 06:21 PM Re: HMDA and Assumptions
Suzie Offline
Platinum Poster
Suzie
Joined: Apr 2002
Posts: 662
Far North
Thanks dpersfull! Your answer is just what I wanted to hear.
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