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#1489703 - 01/05/11 02:32 PM HMDA ?
gunches Offline
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Joined: Dec 2005
Posts: 210
Bank foreclosed on property, customer purchased it on a contract for deed that the bank holds. Is this HMDA reportable????

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#1489708 - 01/05/11 02:37 PM Re: HMDA ? gunches
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
Yes.

Your FI meets the definition of a creditor therefore if your "contract" is payable in more than 4 installments or has interest charges on it you have extended consumer credit and hopefully you provided all the required RESPA & Reg Z disclosures along with performing a FZD, etc.
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The opinions expressed are mine and they are not to be taken as legal advice.

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