HMDA Re-file
Answer by Dan Persfull, BOL Guru Guru Bio
Question: We have existing loans which are being modified to change the payment amount after a large principal reduction and/or a lower interest rate has been negotiated by the customer after again, a large principal reduction. Do we need to re-file this with HMDA to reflect the changes even though the original documentation hasn't changed, i.e., account number, no new credit report, no changes in the Mortgage and/or recordings?
Answer: If it's a true modification then the transaction would not be reportable. If however you are having a new note signed that satisfies and replaces the existing note, then you have a reportable refinancing. You also would have a refinancing for the purposes of Reg. Z and RESPA disclosures.
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