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#144221 - 12/29/03 11:08 PM
Re: HMDA Refi of a non-dwelling secured HI loan
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100 Club
Joined: Apr 2003
Posts: 180
Omaha, NE
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It depends, if your institution classifies the loan as a home improvement loan then the loan is a HMDA reportable loan as a home improvement loan. If the loan is not reported by your institution as a home improvement loan, then I would agree that this type of loan is not reportable for 2004.
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The opinions I express are my own and not the opinions of my employer.
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#144223 - 12/29/03 11:21 PM
Re: HMDA Refi of a non-dwelling secured HI loan
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100 Club
Joined: Apr 2003
Posts: 180
Omaha, NE
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For multi-purpose loans, you use the priority rankings provided by the regulators to determine loan purpose. They are: Home purchase trumps home improvement, home improvement trumps refinance and HELOC trumps all-reporting is optional.
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The opinions I express are my own and not the opinions of my employer.
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#144224 - 12/30/03 02:51 AM
Re: HMDA Refi of a non-dwelling secured HI loan
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Power Poster
Joined: Jun 2001
Posts: 8,272
Where the heart is
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Question: If an unsecured Home Improvement loan falls in the forest and no one was around to hear it, did it make a sound?
Point being - if you CLASSIFY the unsecured loan as Home Improvement, then it's HI regardless if you refinanced anything or not.
Or as I like to think of it - Don't ask, don't tell!
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CRCM,CAMS Regulations are a poor substitute for ethics. Just sayin'
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#144225 - 12/30/03 02:53 PM
Re: HMDA Refi of a non-dwelling secured HI loan
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Anonymous
Unregistered
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Maybe I'm misreading everyone's posts. But my interpretation is that you can only report a unsecured home improvement loan once, at origination. You don't report the refinance. The St. Louis Fed Reserve states that "a refinancing means a new loan that satisfies and replaces an existing loan by the same borrower, in which both the existing loan and the new loan are secured by liens on dwellings. However, the purpose test has been eliminated. Therefore, all loan refinancings secured by a dwelling (where the original loan was also secured) will now be reported, regardless of the purpose of the original or new loan. Likewise, unsecured loans will no longer be reported as refinancings, regardless of the purpose."
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#144228 - 12/30/03 10:06 PM
Re: HMDA Refi of a non-dwelling secured HI loan
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Diamond Poster
Joined: Feb 2003
Posts: 2,362
Colorado
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Non-dwelling secured home improvement loans are still a 2 part test. 1st, a portion of the funds has to be used for home improvement, and 2nd, the loan has to be classified as home improvement. In the original example of refinancing an unsecured home improvement loan, the first test is not met, so it would not be reportable regardless of how it is classified.
If, in addition to paying off the existing loan, the borrower gets additional funds for home improvement, then you could report it as home improvement if it is classified as home improvement.
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Opinions are mine and not necessarily my employer's.
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#144229 - 12/30/03 10:15 PM
Re: HMDA Refi of a non-dwelling secured HI loan
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10K Club
Joined: Aug 2002
Posts: 47,673
Bloomington, IN
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FWIW, I agree with Sar524, HmdaGal and GreatBlue.
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The opinions expressed are mine and they are not to be taken as legal advice.
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#144231 - 12/30/03 10:23 PM
Re: HMDA Refi of a non-dwelling secured HI loan
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10K Club
Joined: Aug 2002
Posts: 47,673
Bloomington, IN
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Are you talking 2003 rules or 2004 rules?
2003 - it would be reportable.
2004 - it would not.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.
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#144232 - 12/30/03 10:33 PM
Re: HMDA Refi of a non-dwelling secured HI loan
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Anonymous
Unregistered
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I would not report it in 2004 unless there was additional money taken out for home improvement purposes.
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