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#140169 - 12/16/03 10:51 PM HMDA Refi
Suzie Offline
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Suzie
Joined: Apr 2002
Posts: 662
Far North
I do not report lines of credit on my LAR. However, in 2004, if I retire a LOC with a closed end loan, I'm going to report this new loan as a refi!
Do ya think I'm getting it right?
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Lending Compliance
#140170 - 12/16/03 11:40 PM Re: HMDA Refi
starfish Offline
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starfish
Joined: Jun 2003
Posts: 416
Seattle
Yes, if the line you are refinancing to a closed end loan is currently dwelling secured and will continue to be dwelling secured!

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#140171 - 12/17/03 03:04 AM Re: HMDA Refi
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I agree.
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#140172 - 12/22/03 05:00 PM Re: HMDA Refi
DebbieC Offline
Member
Joined: Jul 2001
Posts: 66
Owensboro, KY USA
What is the HELOC is replacing a HELOC that was originally for HI or home purchase. Would it be a refinance or not reportable? (We have opted to report HELOCs.)

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#140173 - 12/22/03 05:30 PM Re: HMDA Refi
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,025
Bloomington, IN
Quote:

What is the HELOC is replacing a HELOC that was originally for HI or home purchase. Would it be a refinance or not reportable? (We have opted to report HELOCs.)




It would be a reportable refinance in your case.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#140174 - 12/23/03 12:02 AM Re: HMDA Refi
DebbieC Offline
Member
Joined: Jul 2001
Posts: 66
Owensboro, KY USA
I agree with you, but the "HMDAhelp" tells me that being HELOC trumps the refinancing. So it would not be reportable unless it is for home purchase or HI...that just doesn't make sense with the new definition for refinance. This would mean that every HELOC the refinances another HELOC would not be HMDA reportable, even though the new definition says that it would be. Life shouldn't be this hard.

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#140175 - 12/23/03 01:48 PM Re: HMDA Refi
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,025
Bloomington, IN
I agree this does not make sense per the new definition of a refinance.

The only thing I can think that they are falling back on is in the GIR every reference I found to HELOCs stated to report the amount for HI or home purchase. There was no mention of refinancings, but as we agree, the definition of a refinance should include these HELOCs.

We do not report HELOCs because the dollar amount reporting requirements leaves too much margin for error.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#140176 - 12/29/03 10:24 PM Re: HMDA Refi
Tillie Offline
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Tillie
Joined: Apr 2003
Posts: 266
We have one closing in 2003 but the LOC was for home improvements. We do not report LOC's until they convert to perm financing (if they do). We've discussed this internally and will report as a home improvement on the LAR. Anyone have a different opinion?

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#140177 - 12/29/03 10:29 PM Re: HMDA Refi
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,025
Bloomington, IN
If you are talking about converting a HELOC to a closed end loan, then IMO it would be a refi.

If you are talking about a closed end LOC for home improvements and converting the LOC to a permanent loan when the improvements are complete, then I would report as HI.
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The opinions expressed are mine and they are not to be taken as legal advice.

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