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#1311024 - 12/22/09 02:43 AM Written App on Commercial Loan
Sheldon Hendrix Offline
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Sheldon Hendrix
Joined: Jun 2006
Posts: 1,156
We have recently revised our procedures to require that ALL HMDA transactions must have a written application. I realize that per reg. B, this is a requirement for primary resident purchases, but since we use the app as a source document for several LAR entries, we have requested a written app for all HMDA loans.

Would this be a practicle requirement to ask for on commercial loans (ie, the purchase of an apartment complex). I want to say no, but fear making an exception would circumvent the need for a written app on some HMDA transactions that actually needed one.

Can anyone advise?

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#1311032 - 12/22/09 03:03 AM Re: Written App on Commercial Loan Sheldon Hendrix
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
Many banks use a form for commercial HMDA reportable loans with all required HMDA coding data filled in by the lender (hopefully with GMI completed by borrower if a "natural person").

Some use the official loan approval writeup for the loan amount, borrower name, income used (often in the writeup for calculation of debt service) along with a separate GMI form when required.
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy

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