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#1739904 - 09/11/12 06:26 PM Loan Amount Change
HMDA Specialist Offline
Member
Joined: Mar 2008
Posts: 78
The HMDA Getting it right state that for not originated applications we must to report the originally amount applied for.

They also define a counter offer as when you offer to an applicant to make a loan on different terms or in a difference amount from terms or amount applied for.

If I received an application in the amount of $200,000.00 but the appraisal value do not support the Loan To Value and the loan amount was change to $135,000.00. In this case the application was closed for incompleteness becuase the applicant failed to answer the incomplete letter.

What amount we have to report in the HMDA LAR? The amount originally requested or the lesser amount changed for the appraisal value?

Thanks.

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#1739905 - 09/11/12 06:32 PM Re: Loan Amount Change HMDA Specialist
ComplianceNerd Offline
Gold Star
Joined: Nov 2011
Posts: 378
Texas ...
200,000 and I feel that if your customer never replied to the incomplete letter, it'd be a denial rather than an incomplete application or closed for incompleteness.
Last edited by ETX L Complaince; 09/11/12 06:33 PM.
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#1739915 - 09/11/12 07:00 PM Re: Loan Amount Change HMDA Specialist
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
200,000 and I feel that if your customer never replied to the incomplete letter, it'd be a denial rather than an incomplete application or closed for incompleteness.

I agree with the $200,000 loan amount to be reported but if a Notice of Incompleteness was sent which the applicant did not respond to it would be reported as closed for incompleteness.
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The opinions expressed are mine and they are not to be taken as legal advice.

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