HMDA & Renewing A Residence-Secured Business Loan
by David Dickinson, BOL Guru BIO AND CONTACT INFO
Question: If original loan proceeds were for a business purpose but the loan is secured by mortgage on personal residence, at time of renewing/refinancing that note, does it become HMDA reportable?
Answer: No, at least not under the current rules. The rules that will go into effect on 1/1/04 will capture all refinancings that are secured by a dwelling and pay off a loan that is secured by a dwelling. So if you complete this refinancing before 1/1/04, do not report it as HMDA.
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