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#146506 - 01/07/04 08:16 PM
Dumb HMDA question
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Anonymous
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#146507 - 01/07/04 08:19 PM
Re: Dumb HMDA question
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Anonymous
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I think you would use code 4 if the applicant is a non-person (A corporation for example)
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#146508 - 01/07/04 08:19 PM
Re: Dumb HMDA question
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10K Club
Joined: Aug 2002
Posts: 47,674
Bloomington, IN
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Loans to Corp., LLCs, Partnerships, etc. (not a natural person).
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The opinions expressed are mine and they are not to be taken as legal advice.
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#146509 - 01/07/04 08:20 PM
Re: Dumb HMDA question
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Anonymous
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Code 4 is used if the applicant/co-applicant is not a natural person (i.e. corporation or partnership) or if the information is not available because the loan was purchased from another institution
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#146510 - 01/07/04 08:21 PM
Re: Dumb HMDA question
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Anonymous
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Thanks...
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#146512 - 01/07/04 08:32 PM
Re: Dumb HMDA question
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10K Club
Joined: Aug 2002
Posts: 47,674
Bloomington, IN
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Good catch, and you are absolutely correct.
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The opinions expressed are mine and they are not to be taken as legal advice.
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#146513 - 01/07/04 08:37 PM
Re: Dumb HMDA question
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100 Club
Joined: Apr 2002
Posts: 241
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Well, that's kinda what I thought. Now.....if their ethnicity is Hispanic or Latino, and their race is not American Indian or Alaska Native; Native Hawaiian or Other Pacific Islander; Asian; Black or African American...am I correct in assuming we would check "White"?
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Just when I think I understand....I regain consciousness!!!
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#146516 - 01/08/04 04:10 PM
Re: Dumb HMDA question
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Power Poster
Joined: Apr 2001
Posts: 4,828
Between the lines
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Also, they could be hispanic or latino under ethnicity AND they could be American Indian & African American & White --- multi-racial. The new HMDA allows for 4 choices now under Race.
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#146518 - 01/09/04 12:03 AM
Re: Dumb HMDA question
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Power Poster
Joined: Apr 2001
Posts: 4,828
Between the lines
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Ooops, thanks. I was looking at a sample LAR that only had 4 spaces. Thanks for clearing that up for all us BOL users. I am still trying to figure out how to make our database accept more than one selection --- but that's another HMDA headache.
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#146519 - 01/09/04 09:34 PM
Re: Dumb HMDA question
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Anonymous
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Quote:
Code 4 is used if the applicant/co-applicant is not a natural person (i.e. corporation or partnership) or if the information is not available because the loan was purchased from another institution
What if the applicant is a sole proprietorship (i.e. John Doe dba John's Garage)? Would you automatically choose #4 or would you see if John was going to occupy the property?
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#146521 - 01/13/04 04:45 PM
Re: Dumb HMDA question
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Anonymous
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Quote:
Occupancy is not a factor in collecting monitoring information. Look at how the note is signed. If it's John Doe, dba John's Garage, collect the information. If it's John's Garage, signed by John Doe, Sole Proprietor, use the codes for NA.
I am the anonymous who originally posed the question and my bank's Compliance Officer contacted hmdahelp@frb.org and this is what they said:
A sole proprietorship is not a natural person for monitoring information. Report the customer as John's Garage.
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