06/23/2024
HMDA: If a reportable loan is secured by a residence but the first two borrowers listed it as investment property whereas the third borrower listed it as primary residence, how would you put the occupancy? The first two borrowers are parents of the third borrower, who'll live in the home. Thank you.
01/22/2023
I have a general question about Texas Home Equity law and HMDA reporting. If under Texas law, a home equity loan is considered a refinancing or cash out refinancing regardless of whether the new loan satisfies an existing dwelling secured debt, can that be reported as a refinancing or cash out refinancing on the HMDA LAR?
To my understanding, state law does not impact the reporting of loan purpose under HMDA rules. If a new loan does not satisfy an existing dwelling secured debt, should it be reported as refinancing or cash out refinancing?
I’m specifically referring to the Texas A6 Home Equity loan product. Under Texas law, this product is always classified as refinancing or cash out refinancing regardless of any other definition of refinance.
02/20/2022
When there is conditional approval to an applicant for a HELOC based on stated income, but the applicant hasn't provided any of the requested documents to substantiate the income, is this a denial because we are unable to verify income or approved not accept by the borrower?
07/18/2021
When populating the collateral address for consumer closed-end, real estate secured loans (TRID), is there an industry best standard for WHERE we obtain this address from? I know that it must always include the zip code, and a location (if an address via US Postal Service is not available), but I'm curious if there is an unspoken standard of what document this is best obtained from, such as the counties property record card, the written evaluation provided to us from a certified appraiser, borrower attested to, etc.
06/27/2021
What does “GMI” mean in banking?
03/31/2019
Is Letter of Credit to secure a Bond for the purpose of purchasing a residence HMDA reportable?
03/10/2019
I have a mortgage that has been approved, commitment signed and returned, all conditions have been met by the borrower. Borrower has now decided to withdraw. How do I code this? It is not a withdrawal, not a decline. Would it be approved not accepted?
03/10/2019
We have a loan for $3,372,000 that is HMDA reportable and we are going back and forth on how this should be rounded. Do we report 3400 or 3372 on the LAR?
02/03/2019
Are there possible compliance violations with Regulations B & C and UDAAP if denial reasons are different on the HMDA LAR than what was on the Notice of
Adverse Action? For example: at the time of decline, the denial reason listed on the NOAA was "Other", but when the file was reviewed for HMDA data
validation, the true denial reason should've been a Collateral decline.
07/15/2018
Two years ago we granted a new loan and took a first mortgage on a piece of vacant land as collateral. The loan is now going through a renewal. While completing the evaluation, we learned that the borrower; using his own cash, built a home on the property that’s encumbered. The way our mortgage reads, we have interest in ... all existing or subsequently erected or affixed buildings, improvements, and fixtures...
When we complete the valuation report, should the value of the home be included in the report and furthermore, if so, should the report be mailed to the borrower under Regulation B?