Refinance a loan secured by two properties. The property reported is a first lien, but on the lien status on the HMDA is marked subordinate lien. The other home securing home is a second mtg.

My question is does it matter that we reported the first lien on the HMDA worksheet but coded as a second lien. Regulation C states report the lien status of the dwelling securing the loan. So, I'm thinking it doesn't matter.

Also, on the rate spread calculation the lien status that was enter was second. So, the rate spread came back NA. The property with the second lien is their primary dwelling.

When you select which property to report, you must report all data related to that property. Mixing it up makes the data meaningless.

Pick one property, use the same property for geocoding, lien status, owner occupancy. It doesn't matter if you are using 1 or 2 properties as collateral to buy another dwelling; all that does is give you the purpose of the loan.

Kathleen said the same thing, I am just being more specific since I got all confused on some of these when we first started reporting.