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#127399 - 10/31/03 05:29 PM HMDA Revisions (Application)
Georgia Golfer Offline
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Georgia Golfer
Joined: Jun 2003
Posts: 415
1st Tee
It's my understanding that if we start a loan this year, but do not close until after the 1st, it is most certainly subject to the HMDA revisions of '04. True? I ask this in relation to the new applications & a memo that the mortgage dept got from one of the investors. Talk about a monkey wrench...

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Lending Compliance
#127400 - 10/31/03 05:41 PM Re: HMDA Revisions (Application)
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
Quote:

It's my understanding that if we start a loan this year, but do not close until after the 1st, it is most certainly subject to the HMDA revisions of '04. True?



True.

Also keep in mind that the new applications are not effective until 1/1/04.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#127401 - 10/31/03 06:02 PM Re: HMDA Revisions (Application)
Georgia Golfer Offline
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Georgia Golfer
Joined: Jun 2003
Posts: 415
1st Tee
Ok, so does that mean they complete an old app when they apply on Dec 31, 03 and then sign, date and fill in the new info at closing on Jan 28, 04 with a new app?

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#127402 - 10/31/03 06:30 PM Re: HMDA Revisions (Application)
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
Yes, that's where the transition rules come into play.

Let me rephrase, you would not have to complete a new app, but you would have to record the information per the transition rules.
Last edited by dpersfull; 10/31/03 06:31 PM.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#127403 - 11/03/03 06:07 PM Re: HMDA Revisions (Application)
Anonymous
Unregistered

Quote:

Ok, so does that mean they complete an old app when they apply on Dec 31, 03 and then sign, date and fill in the new info at closing on Jan 28, 04 with a new app?



In your original question, you referred to a memo from an investor. Many investors require a an application to be signed at closing, which I assume prompted your question. We called our investors to confirm that if the application was taken in 2003, that we could print out the 2003 version to be signed at closing, even if the closing occurred in 2004. The electronic file delivery requirements do differ.

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