Situation:
Customer purchases home (primary residence) with intent to sell other home. Sale of other home will pay-off new loan. The new loan is for one year (balloon).
Questions: We are a HMDA reportable bank. There is conflicting information as to rather we would report this loan under HMDA or not. It is temporary but will not be replaced by new financing. Does that make it HMDA reportable? Or does the temporary financing exclusion apply?

If the temporary exclusion applies for HMDA and we would not report, do we still need to collect certain montioring information under Regulation B, or would the temporary exclusion rule on that too?
Any help is appreciated. Thanks.

We would report this as a purchase for HMDA as it is not temporary financing, just short term.

I agree and also Reg B only exempts the initial construction loan as a temporary loan. There are no other temporary loan exemptions in Reg. B.

Thank you Dani and Dan for your input.

One last question....If a loan is to be secured by the applicants primary residence and it is not HMDA reportable (such as a bridge loan) would you still collect the GMI under Regulation B if you are a HMDA reportable bank? (I've been given some conflicting information on this.)

Reg B requires GMI on purchase and refi of purchase money loans. If it fits that category (Bridge = Purchase), then yes.

Reg B requires GMI on purchase and refi of purchase money loans. If it fits that category (Bridge = Purchase), then yes.

(I've been given some conflicting information on this.)

Check out this previous discussion and it should help clarify the requirements.

I'm sure I'm missing the obvious, but I struggle with the definition of a bridge loan. Why wouldn't this be considered a bridge loan (bridging the gap between the purchase of a new home & the sale of an old home)?

Thanks.

The loan is termed out as a one year balloon note, or that is what is implied to me by the post, therefore it would not be a bridge loan but the permanent financing of the transaction.

For Reg B purposes, even if it qualified as a bridge loan, it would not be exempt from the GMI requirements.