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HMDA Triggering Loan
Answer by Dan Persfull, BOL Guru
Guru Bio
Question: For HMDA reporting, does a HMDA-triggering loan (at least 1 first lien home purchase loan secured by a 1-4 family dwelling in a calendar year) have to be to an individual or is it triggered even if the borrower is a corporation or LLC?
Answer: What you are referring to is for coverage purposes, not reporting purposes. From page C-3 of the GIR:
(1) For coverage purposes, the existing obligation is a home purchase loan (as determined by the lender, for example, by reference to available documents; or as stated by the applicant), and both the existing obligation and the new obligation are secured by first liens on dwellings; and
(2) For reporting purposes, both the existing obligation and the new obligation are secured by liens on dwellings.
The definition simply refers to a home purchase loan, it does not differentiate between consumer or business.
First published on BankersOnline.com 11/05/07
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