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Home Equity Loan, Rental Property Collateral, and HMDA
by Todd Cooper, PCI

Question: have a loan that I am not sure if it is subject to HMDA. Purpose is to purchase real estate. Collateral is rental property they already own. The loan is home equity(close end). We have a 2nd mtg. on rental house. Is this subject to HMDA?

Answer: Two additional pieces of information are needed to answer this question completely:
  1. What kind of property is being purchased? Is it residential or commercial?
  2. Does the institution currently report home equity loans?
If it is residential and the institution reports home equity loans, then they should report it under HMDA.


Todd Cooper
EVP, CRA Products
PCi Corporation
617 535-3000

First published on BankersOnline.com 8/4/03








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