05/16/2011
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?
02/28/2011
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?
01/24/2011
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?
12/13/2010
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?
11/08/2010
Our bank is making a loan for the purchase of nine duplex units. When completing the HMDA LAR, would the property type be a one-to-four family (Code 1)or a multi-family (Code 3)?
11/08/2010
Is there a timing issue for HMDA reporting? Assuming we meet all other requirements, we have loans where the purpose is to purchase a dwelling, but the applicant has had to pay cash because it was a foreclosure, and we have loans for home improvement, where the improvement has been done with cash and the applicant wants to be reimbursed through loan proceeds. Are these HMDA reportable, or do the proceeds have to be used for the actual purpose?
11/01/2010
We are refinancing a loan that is secured by two manufactured homes and one dwelling. What property type code should be used on the HMDA LAR?
10/25/2010
I have a loan on my LAR that was closed for incompleteness. The customer never provided the necessary income information needed to verify debt to income; therefore, there is no income to report. What do I provide in the Gross Annual Income area for HMDA?
07/26/2010
An applicant refused to answer any of the monitoring questions during a telephone application, but during the review of the typed application, he marked the appropriate boxes. Do we include the updated information on the HMDA LAR or leave it as things he does not wish to disclose? The HMDA "Getting it Right" says that we are not required to report the information, but the FFIEC Q&As say that it would be a violation to report the updated information. Could you please tell us if it is a violation to include the customer provided information and share the basis for your answer?
05/17/2010
If an individual uses his personal residence as collateral for the purchase of a rental home, is this a business purpose under HMDA? If not, how do I show his approved application (loan not closed/funded) on the LAR?