I attended a seminar last week and I discovered that our bank, which I thought was approving and selling loans, was actually acting as a broker. Upon speaking to the primary loan officer for these loans I found out that we do not do any of the underwriting for these loans, nor do we make the credit decision. The purchaser is putting these loans on their LAR (as they should), but so have we. I have been working here nearly a year now and just found that information out and I am upset with myself for not knowing this information before now. I looked at our LAR from last year and see that nearly half of the loans on the LAR should not have been reported as they were these brokered loans. It is the same story as far back as 2014. Do we
need to go back and re-submit the LAR(s) or can we proceed as normal? Are we looking at penalties? I am really shocked at this news. After several exams and outside audits, this was never discovered until now. I would really appreciate any tips you can offer.
HMDA - GMI: two applicants but only one signed the note. What GMI do we report on the LAR?
I have a loan for 3.7 million secured by 2 commercial buildings and (8) 4-plexes. We split our entries on the LAR. Would I divide the 3.7 million by 8 (the dwellings)and report as 8 entries on the LAR?
I have a HMDA question. I have loan that is to purchase an apartment complex, 60 apartments in 5 separate buildings. Do I report this all at once or do I report each building separately?
For HMDA purposes, how is the following loan to be reported? The bank made a construction-only loan with a 12-month maturity. The home was completed as of the maturity date, but the borrower needed time to sell the home. In the interim, the bank makes a loan for 12 more months that we consider temporary financing. At the end of this term, we make another loan to convert the initial construction to permanent financing and report it on our LAR as a home purchase loan. Is this correct? Is there a rule that says the “permanent financing” has to immediately follow the construction loan?
According to HMDA, should collateral that contains both 1-4 Res and Multi-family property on the same complex be coded as 1-4 or Multifamily on the LAR?
A borrower owns his primary dwelling free and clear. The borrower wants to take cash out to purchase another dwelling using only his primary dwelling as collateral. Is this loan HMDA reportable?
The bank made a $1,000,000 HMDA reportable loan in February, then in November gave the borrower another $500,000 under the future advance clause. Borrower requested the additional funds and bank granted the request after reviewing credit, etc. This bank is FDIC regulated. Should this future advance be reported on the LAR as a separate line item under the same loan number as one other regulator previously required or, if not, how should it be reported?
We are trying to clarify an item from the Official Staff Commentary of Reg C - 2(g) Home Improvement loan. The commentary indicates “Classification requirement for loans not secured by a lien on a dwelling. An institution has “classified” a loan that is not secured by a lien on a dwelling as a home improvement loan if it has entered the loan on its books as a home improvement loan, or otherwise coded or identified the loan as a home improvement loan.” We have not reported any loans to our Call Report as home improvement nor are any identified as home improvement in our underwriting summaries or on our core system. However, in review of loan notes, the purpose is stated to be for a "new roof", but not specifically home improvement and it’s not "classified" as stated above as home improvement. The loan is for a condominium complex with assessments as collateral. Should this loan be included on the HMDA LAR as home improvement?
For business loans that are HMDA reportable, do we input a rate spread on the LAR even though there is not an APR defined by TIL, or do we not report the rate spread for busines loans and report them all as N/A?