Skip to content
BOL Conferences
Thread Options
#1683365 - 03/28/12 08:10 PM HMDA ??
markp Offline
Gold Star
Joined: Jan 2007
Posts: 382
New Jersey
With regards to a cash out if a client tells us that he is using the funds for Investment, do we have to have documented what the investment is,or can we list it as an investment?

Return to Top
Lending Compliance
#1683380 - 03/28/12 08:25 PM Re: HMDA ?? markp
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
Investment covers a lot of ground - is he investing in a rental dwelling - is he investing in the stork market - is investing in a business venture - is he investing in a piece of land for resale - is he investing in his bankruptcy attorney - is he investing in a marijuana field - is he investing in a home improvement project - is he investing in a vacation home -

There are investments mentioned above that would cause the loan not to be reported as a refinance.

Also check out page D-10 of the GIR
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#1683381 - 03/28/12 08:25 PM Re: HMDA ?? markp
WI Banker Offline
Gold Star
Joined: Dec 2006
Posts: 253
You need to find out what the investment is, otherwise you won't know if it's HMDA reportable or not.

Return to Top
#1683536 - 03/29/12 01:42 PM Re: HMDA ?? WI Banker
markp Offline
Gold Star
Joined: Jan 2007
Posts: 382
New Jersey
Thanks Dan & WI
How should it be handled in the event we know they are going to invest the funds from the cash out but they don't know what the investment is going to be?
Last edited by markp; 03/29/12 01:43 PM.
Return to Top
#1683556 - 03/29/12 02:14 PM Re: HMDA ?? markp
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
but they don't know what the investment is going to be?

Then I would be skeptical of the true purpose of the loan. The borrower must have some idea of what they are going to invest in otherwise why go through the expense of getting the money until they do?
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top

Moderator:  Andy_Z