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#1606261 - 09/20/11 09:17 PM HMDA Question - Consumer and Commercial RE
RGS Offline
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RGS
Joined: Jul 2002
Posts: 689
Home of the 8 time NCAA Champ ...
We think we're right, have read previous posts, the Q&A, staff interpretations, Getting it Right, consulted our Magic 8 Ball, and Miss Cleo. With that said, we'd still like a 48th opinion.

We have a loan that is the permanent financing of a construction loan on commercial RE. The loan also has a second mortgage on non-owner occupied residential RE owned by the same borrower to provide extra equity.

We're comfortable that the construction loan with the purpose to construct commercial property was not HMDA reportable. However, we're convinced that the separate loan to provide permanent financing is HMDA reportable since it is a refinance of a dwelling secured loan. This seems counter-intuitive and makes no sense, but we can't find any other thing to tell us that we're wrong. Are we right?

TIA
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#1606267 - 09/20/11 09:24 PM Re: HMDA Question - Consumer and Commercial RE RGS
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
If you are doing a dwelling secured loan (no matter how much of it is dwelling secured) that is a refi of a dwelling secured loan to the same borrower it is HMDA reportable. Makes no sense, never did since this change came through a while back and start sweeping many commercial deals into HMDA.
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#1606268 - 09/20/11 09:25 PM Re: HMDA Question - Consumer and Commercial RE RGS
TMatt87 Online
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TMatt87
Joined: May 2011
Posts: 1,984
Idaho
I would agree with you. A dwelling secured loan that replaces another dwelling secured loan is a HMDA refinance.

KB beat me by 8 seconds grin
Last edited by TMatt87; 09/20/11 09:27 PM.
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