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#1755464 - 11/06/12 04:28 PM HMDA Reportable or Not???
Linkpars Offline
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Joined: Jan 2007
Posts: 179
Kentucky
We have a customer who owns their home free & clear. They have decided to help their son purchase a home. So they use their home as collateral, the apprasial is on their home with no information on the home that their son is purchasing. They have just given him the money.

So they did not purchase their home, refi, and no home improvements were done. I don't think this is HMDA reportable since the purpose of the loan actually did not fall in these three catagories, just wanted a second opinion.

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#1755479 - 11/06/12 04:42 PM Re: HMDA Reportable or Not??? Linkpars
Tater Offline
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Joined: Jan 2006
Posts: 623
Missouri
I disagree. Purpose is to purchase a home (although not theirs). Collateral is a residential dwelling, although not the dwelling being purchased. Page 28, GIR.

On page D-5 of the appendix, "a home purchase loan includes a loan secured by one dwelling and used to purchase another dwelling."
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#1755493 - 11/06/12 04:52 PM Re: HMDA Reportable or Not??? Linkpars
raitchjay Offline
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OK
But unless the parents will also be on the title to the son's home, your borrowers (the parents) aren't purchasing a home. What a non-borrower (the son) does with the money is irrelevant. They're giving their son a gift. I vote not reportable.
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#1755495 - 11/06/12 04:53 PM Re: HMDA Reportable or Not??? Linkpars
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
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Bloomington, IN
Unless the parents are actually purchasing the home themselves this would not be a home purchase loan. The proceeds of this loan are being used as a gift to the son. What he does with the gift is of no consequence for the classification of the parent's loan.
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#1755497 - 11/06/12 04:56 PM Re: HMDA Reportable or Not??? Linkpars
Linkpars Offline
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Joined: Jan 2007
Posts: 179
Kentucky
The parents will not be on the title, they are only giving the money to the son. Like a gift you could say to use as he sees fit to purchase a home for himself. The parents are also not purchasing the home.

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#1756331 - 11/08/12 01:56 PM Re: HMDA Reportable or Not??? Linkpars
Indy Banker Offline
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Joined: Aug 2010
Posts: 528
We've had several loans like this lately and have considered them not to be HMDA-reportable, consistent with what Dan's guidance states.

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