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#128950 - 11/06/03 05:28 PM HmDA denial for temporary financing
Tillie Offline
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Tillie
Joined: Apr 2003
Posts: 266
Is a denial for an application for temporary financing reportable? The Guide states that "temporary financings" are not reportable but, in my feeble mind, I always thought that just referred to loans funded and not applications.

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Lending Compliance
#128951 - 11/06/03 05:33 PM Re: HmDA denial for temporary financing
RR Joker Offline
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RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
To me the BIG question would be...what is your definition of temporary financing? If you have a definite payout agreement, even it it's a 3 month loan, it's not temporary. If someone outside is involved in the payout, then it's probably really temporary and not reportable. I'm not the HMDA expert here, but we have batteled the true definition of "temporary" around here a good bit lately.
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#128952 - 11/06/03 05:41 PM Re: HmDA denial for temporary financing
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
As Joker alluded a short term loan is not necessarily a temporary loan, but if the loan is a temporary loan request then it is not reportable (approved, withdrawn or denied).
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The opinions expressed are mine and they are not to be taken as legal advice.

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#128953 - 11/06/03 08:57 PM Re: HmDA denial for temporary financing
Tillie Offline
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Tillie
Joined: Apr 2003
Posts: 266
If I understand you right, we use the same criteria for application denied as we would for loan funded to determine if it is temporary and reportable or not. In our case, we look at both terms of the loan and source of repayment.

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#128954 - 11/06/03 09:12 PM Re: HmDA denial for temporary financing
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
The best example I can think of is a "swing/bridge" loan. These are temporary loans and are not HMDA reportable. If the "swing/bridge" loan is denied, that doesn't change the fact it was for temporary financing. This denial is not reportable.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#128955 - 11/10/03 04:31 PM Re: HmDA denial for temporary financing
Tillie Offline
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Tillie
Joined: Apr 2003
Posts: 266
Thank you for all your help. I think I have it straight now.

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