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#1325744 - 01/15/10 08:37 PM HMDA Questions - New To Compliance
Big Blue Banker Offline
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Big Blue Banker
Joined: Apr 2009
Posts: 305
I have two HMDA questions...

1.) If a loan is not HMDA reportable at origination (example, using the funds to purchase a car and securing it with your home) and that is refinanced...would that then be HMDA reportable? (Dwelling secured replaced by dwelling secured)

2.) If an obligation is refinanced at the beginning of 2008 and then again at the end of 2008, and is HMDA applicable, would you report BOTH refinances or just one per year?

Thanks!

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#1325794 - 01/15/10 08:59 PM Re: HMDA Questions - New To Compliance Big Blue Banker
hmdagal Offline
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hmdagal
Joined: Dec 2002
Posts: 3,819
1. yes, it's reportable
2. both refis are reportable

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#1325863 - 01/15/10 09:32 PM Re: HMDA Questions - New To Compliance hmdagal
Big Blue Banker Offline
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Big Blue Banker
Joined: Apr 2009
Posts: 305
Thanks HMDAgal. I found documentation for my first question, do you know of any place I could get the second question in black and white? Not that I don't trust you! I just need some more backing, haha smile Thanks!

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#1325867 - 01/15/10 09:36 PM Re: HMDA Questions - New To Compliance Big Blue Banker
Doin it right Offline
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Joined: Mar 2006
Posts: 245
Up North
You may be thinking of CRA when you wonder about a refi the same year.

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#1325897 - 01/15/10 09:53 PM Re: HMDA Questions - New To Compliance Doin it right
hmdagal Offline
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hmdagal
Joined: Dec 2002
Posts: 3,819
Banker Bee, you won't find anything saying you don't report the second refi, so it falls under the regular refi definition. Sorry about the double negative - I hope that makes sense.

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