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#1090316 - 12/02/08 05:41 PM Commercial Loan refinance - HMDA reportable?
tjbanker Offline
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Joined: Jun 2002
Posts: 310
Okay. Loan was originally completed as a commercial loan on a multi-family dwelling. The loan is now being rewitten. If this loan is refinancing a dwelling secured loan it would be HMDA reportable, correct? I am seeing this definition on the GIR guide page 29. Do they still need to be initially for the purchase or home improvement of a dwelling? Brain fog today.

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#1090320 - 12/02/08 05:44 PM Re: Commercial Loan refinance - HMDA reportable? tjbanker
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Correct. A "refinance" does not need to be initially for purchase or home improvement. That changed in 2004.
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David Dickinson
http://www.bankerscompliance.com

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#1090326 - 12/02/08 05:48 PM Re: Commercial Loan refinance - HMDA reportable? David Dickinson
tjbanker Offline
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Joined: Jun 2002
Posts: 310
Thanks for the quick reply!

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