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#1371446 - 04/08/10 07:05 PM is this HMDA reportable?
gunches Offline
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Joined: Dec 2005
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Customer borrowed money to do home improvements, using CD for collateral. Loan was coded for homeimprovement on our books.
It was a 3 month loan, to be paid from cashing in the CD we used as collateral. Is this HMDA reportable?

Is there a place to find more information on temporary financing in regard to HMDA

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#1371490 - 04/08/10 07:56 PM Re: is this HMDA reportable? gunches
Relax Offline
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Not dwelling secured, NOT HMDA unless you code your Home Improvement files in some way to differentiate them.
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#1371584 - 04/08/10 09:18 PM Re: is this HMDA reportable? Relax
gunches Offline
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It is coded as a home improvement loan on our software - My question was more regarding the short term financing issue and the method of repayment. I thought if a loan was going to be repaid by putting it into permanent financing, it would not be reportable. But if was going to be repaid by some other means, it would be reportable.
Any clarification??

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#1371604 - 04/08/10 09:45 PM Re: is this HMDA reportable? gunches
raitchjay Online
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It doesn't sound to me like your loan is designed to be replaced by permanent financing. It's designed to be paid off with the sale of the CD. I think it is short term financing, not temporary financing. I think it is HMDA reportable.
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#1371755 - 04/09/10 02:16 PM Re: is this HMDA reportable? raitchjay
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
I agree. Short term financing, not temporary financing. The loan is reportable since it is for HI and it was classified as a HI loan.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1373214 - 04/13/10 03:14 PM Re: is this HMDA reportable? Dan Persfull
Destin8 Offline
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Joined: Apr 2010
Posts: 26
We have not reported applications for the purpose of home improvement if they were not dwelling secured. Since this is a new issue, suggestions for the following would be appreciated:

[list]
[*]Collateral is vacant land, but notes in the file/system state funds will be used for home irmprovement; is this still reportable since loans on vacant land should not be?

[*]If CD secured and notes in file/system state funds will be used for home improvement, do you use the customers address as the collateral address?

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#1373250 - 04/13/10 03:54 PM Re: is this HMDA reportable? Destin8
raitchjay Online
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1) Non-dwelling secured HI loans need to be "classified" by your institution as home improvement loans to be reportable. If notes in the system means something as simple as "home improvement" showing up on the boarding data, i don't believe that meets the test of being "classified". If however, they show up on a call report as "home improvement" loans, they would be classified as such and reportable imo.

2) Again, i would determine to my satisfaction whether my institution was truly "classifying" these as home improvement. If they are being classified as such, the property to use for owner occupancy and to geocode would be the property being improved.
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#1373551 - 04/13/10 07:44 PM Re: is this HMDA reportable? raitchjay
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
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Bloomington, IN
Quote:
Loan was coded for homeimprovement on our books.


If they can pull a report by this code for all loans coded as HI loans they have classifed them as such and they would be reportable.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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