Our bank extended an unsecured loan to a borrower to purchase a home. The unsecured loan was temporary until the mortgage file was ready to close. I'm thinking that the permanent mortgage file should be reported as a home purchase even though we are treating like a refinance. I'm following the same philosophy as the construction to permanent loan files. Is this correct thinking?
When do we start collecting the new fields required in the HMDA update and when will we be required to start reporting those new fields?
I have read conflicting discussions about how to report a loan on the LAR. We have a loan secured by the primary residence, proceeds used to purchase a piece of rental property. Which property should we report?
Is an unsecured loan for an above ground swimming pool, to replace an existing pool damaged by weather considered HMDA? I know it would be if a pool had not already been in it's place, but being as there was once one existing there, I am little hazy on it.
If we originate a reportable loan and subsequently sell it, servicing released, is it reportable on our HMDA LAR?
by John Burnett
There are five areas where law or regulation mandates training for bank employees: