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#1756511 - 11/08/12 07:34 PM dwelling secured demand loan - HMDA reportable
Sheba Offline
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Sheba
Joined: Mar 2002
Posts: 73
Oz
I have a dwelling secured interest only demand loan that has been converted to a amortizing 25 year ARM loan As the change was done using a modification agreement rather than a new note--I am assuming this will not be HMDA reportable. Just a little confused by the circumstances, but hoping someone can let me know if I am looking at this correctly.

Thanks to all.

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#1756664 - 11/09/12 01:46 PM Re: dwelling secured demand loan - HMDA reportable Sheba
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,460
Bloomington, IN
Modifications are not reportable.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1756700 - 11/09/12 02:45 PM Re: dwelling secured demand loan - HMDA reportable Dan Persfull
Sheba Offline
Member
Sheba
Joined: Mar 2002
Posts: 73
Oz
Thanks Dan. Appreciate the confirmation.

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#1756784 - 11/09/12 04:36 PM Re: dwelling secured demand loan - HMDA reportable Dan Persfull
JSD Offline
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JSD
Joined: Oct 2000
Posts: 512
USA
Dan is right in that mods aren't reportable except for one situation that would be:

The Second Quarter 2011 issue of Consumer Compliance Outlook is now available on the Outlook website:

http://www.philadelphiafed.org/bank-reso...a-reporting.cfm

If the bank modifies, but does not refinance, a temporary construction loan into permanent financing, does this loan become a HMDA-reportable loan?
Yes. Comment 203.2(h)-5 explains that when permanent financing replaces a construction-only loan, the loan should be reported for HMDA. In addition, construction-permanent loans must also be reported for HMDA. In essence, the bank has replaced its temporary construction loan with permanent financing through this loan modification. Because it is no longer a temporary loan and has not been previously reported, it should be reported as a home purchase loan if it meets Regulation C's definition of home purchase.

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