If a loan application indicates the purpose of a loan secured by a time deposit is for home improvement, would this purpose satisfy how the bank "classified" this particular home improvement loan under HMDA?

No. If you do not "classify" these loans either by a system code, color file folders, segregated filing area, etc. I would not consider them classified.

Thank you..I appreciate your assistance.

If the loan is classified as a HI loan but it is refinanaced and is secured by stock, is this reportable? The original loan was for HI and secured by stock. At first we thought no since we thought we understood that for a refinance, both loans had to be secured by a dwelling. But this is a HI loan. In reading the definition of Refinancing in the HMDA Getting it Right it appears to indicate that purpose does not matter. Your help is appreciated.

We would not report this loan as a refinance or HI.

FWIW, we have taken the advice of David Dickinson and we will no longer report HI loans not secured by a dwelling. We have reclassified what few loans we had for the 1st quarter and will no longer classify them as HI loans in the future.

Could you go into a little more detail as to why you won't be reporting HI not secured by a dwelling? What is David's advice?

The Anon post to Dpersfull is mine, I'm sorry I forgot to login. Thanks!

That's my advise all right.

I wish I had taken David's advice. I think it may be too late now that we have loans that may/may not be reported. We could reclassify them, but the lenders probably collected the monitoring information. We're starting a review of the 1st quarter which should be interesting! It would definitely have made this refinancing mess a little easier to deal with. Thanks!

I think you can draw a "line in the sand" and stop with this HI loans. You might want to talk to your regulator about it to get their blessing.

We also stopped classifying HI loans last year. Best thing we ever did! Of course, this year we will have to report them if they are dwelling secured, but it is much easier for our loan officers to remember.

We classify by much the same way - it is marked HI on the application and on the worksheet that the lender sends to the funding desk it also has Home Improvement typed on it so our loan processing assigns it a purpose code of HI. Is this not a real classification system? If you choose to stop reporting the unsecured ones - I am curious about the GMI that's already been collected on those applications taken year to date?

We classify by much the same way - it is marked HI on the application and on the worksheet that the lender sends to the funding desk it also has Home Improvement typed on it so our loan processing assigns it a purpose code of HI. Is this not a real classification system? If you choose to stop reporting the unsecured ones - I am curious about the GMI that's already been collected on those applications taken year to date?

What about loans that do not come in as HI but the borrowers get cash back? In two seperate HMDA seminars last year we were instructed that if even so much as a doorknob is purchased, the loan is HI for HMDA purposes. We've developed a form that borrowers sign at closing answering yes/no to 2 questions: Are you getting cash back? Will any of it be used for HI? Anyone else doing anything like this?

We report the portion that is for HI.

We obtain the purpose of the cash back & record it on the loan application. We don't use a separate form.

According to 2004 Getting It Right! if any portion of the loan is for HI then the entire loan is reported as HI. So, Joker, how do you "...report the portion that is HI"?

I'm sorry bip..I was thinking HELOC, which if any portion is for HI , actually you only report the first draw or HI portion, whichever is less(according to our in-house HMDA officer.

If it were say, a 2nd mortgage and part was for HI, then the entire loan is reported.