I have a customer that currently has a real estate loan and an equipment loan with the bank. He wants to combine the loans and get funds to start a new business. Do I give him an application with monitoring information, or without monitoring information?
Our bank is new to HMDA reporting for 2004. If a loan originated prior to 2004 that was for the purpose of purchasing a dwelling or for home improvement, and is now up for renewal, should it be reported now? I understand that a renewal, modification, or extension of existing debt is not reportable for HMDA purposes, but in this case, should it be reported?
I participated in the January 12 HMDA seminar, and have a question from the materials. On page 12, I need some clarification on the definition of Refinance. 1) Could you define the distinction between 'coverage purposes' and 'reporting purposes'? 2) It states that "...the existing obligation is a home purchase loan..." Does this mean that a loan that has already been refinanced in the past does not qualify? How about a refinance of a home improvement loan?
A customer purchased rental property with a line of credit at another bank. We are refinancing the loan, and taking a first deed of trust on the property. Is this HMDA reportable? I have been told that on business purpose loans that get refinanced from one bank to another are excluded. Is this correct?
Is a mobile home HMDA reportable? Does it matter if they are permanently attached to a property or not? Are there any differences in mobile homes in general, or are they all considered the same as far as reporting goes?
Is a mortgage transaction subject to right of rescission under the following scenario? A Customer is buying a property on contract, does not currently live in the property, but intends to live in it at "some point" in the future.
If a customer is refinancing a 2nd home or investment property are we required to give them the When Your Home is on the Line booklet?
There are some interesting facts about the 2004 HMDA submission that put a bit of perspective on the reporting process.
Do Regulation O provisions apply to mortgage loans extended to executive officers which are sold to investors by the bank? These loans have an investor commitment up front and are held by the bank for 30-60 days only before sale. Also, mortgage refinancing provisions appear to exclude equity extraction mortgage loans unless the proceeds are used to further improvements in the primary residence. Is this an accurate interpretation?
Question: We are making a complicated loan to a customer. The customer is making significant improvements to his house and also wants to refinance the existing mortgage.