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#1855040 - 09/24/13 07:06 PM Temporary Financing
BNH Offline
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BNH
Joined: Feb 2013
Posts: 108
We have a loan that is going to be refinancing another loan, both with residential properties as collateral. The loan is only for 12 months which could make it not HMDA reportable. However, the repayment of the loan is not from another loan it will be from an inheritance. Does this make the loan HMDA reportable?

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#1855044 - 09/24/13 07:08 PM Re: Temporary Financing BNH
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
The loan is a short term loan, not a temporary loan. It's a reportable refinancing.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1855334 - 09/25/13 04:23 PM Re: Temporary Financing BNH
Glo Offline
Gold Star
Joined: Jul 2005
Posts: 394
Arkansas
This below is what a loan assistant sent me in an email asking if we report this for HMDA. I thought I would post it on BOL to see what you think. I have been scatter brained lately and do not trust my own judgement these days. What do you think?

I am doing a loan (6 month term) to payoff an unsecured loan and payoff a loan that we originally made to purchase a investment residential property (we did HMDA at this time).
He is now combining the two together for six months with hopes that it sells.
Do I do HMDA again? It is secured with the investment property.
I think so unless the term trumps it.

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#1855366 - 09/25/13 05:19 PM Re: Temporary Financing BNH
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
This would also be a short term loan and reportable.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1855395 - 09/25/13 06:06 PM Re: Temporary Financing BNH
Glo Offline
Gold Star
Joined: Jul 2005
Posts: 394
Arkansas
Okay, thanks Dan!

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#1855425 - 09/25/13 06:49 PM Re: Temporary Financing BNH
compliancecrazy Offline
Member
compliancecrazy
Joined: Jun 2006
Posts: 98
Southeast
I have a question similar to this one. A loan to renovate a home, closed end, draw down LOC. What if our repayment is either to be paid in cash OR convert to a HELOC? My thinking is to report, since there is uncertainty if this loan is to be replaced by a financing of a longer term. Thoughts?

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#1855437 - 09/25/13 07:05 PM Re: Temporary Financing BNH
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
If the primary repayment source is the cash and the refinancing is a secondary source I too would report it.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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