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#1721640 - 07/19/12 07:28 PM HMDA Reportable Purchase?
AuditorK Offline
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Joined: Feb 2003
Posts: 961
PA
Borrower applies for $150,000 to pay off two existing private loans and pay closing costs with the new loan. The new loan will be secured by two properties - both owned by the parents. As part of the transaction, one of the properties will be deeded over to the borrower (son & daughter-in-law).

Seems like a HMDA reportable purchase in disguise to me. What say you?

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#1721658 - 07/19/12 08:01 PM Re: HMDA Reportable Purchase? AuditorK
ComplianceNerd Offline
Gold Star
Joined: Nov 2011
Posts: 375
Texas ...
It definitely does seem like a purchase in disguise.

I'd say that yes it is a purchase actually.
I've seen similar situations where individuals owned rental property then decided to create an entity and deeded it over to the new company. To the individual it was a refinance but for HMDA it is a purchase.
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