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HMDA File Review - LAR Requirements
Answer by Dan Persfull, BOL Guru
Guru Bios
Question: I'm doing a HMDA file review (I am new at this) and have been given some commercial loans. Are the LAR requirements identical to individuals? Where can I find guidance on this?
Answer: They are similar but not identical. Rate spread will not apply to business purpose loans, it only applies to loans subject to Reg Z. For certain categories, income as an example, you will report N/A if the borrower is not a natural person. Doing a keyword search of the GIR will give you the guidance you need. http://www.ffiec.gov/hmda/guide.htm
First published on BankersOnline.com 2/04/08
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