HMDA or not?
Application declined on a commercial R/E loan (purpose of loan was for working capital)to be sucured by 3 known residential properties. It is unknown if the properties were owned free and clear or not. The app was declinded so we did not do a title search.
Would you report this as a declined refinance or not report at all since the bank has no knowledge if there were liens or not...
Thanks for you opinion in advance!
Opinions expressed are my own and do not necessarily reflect those of my employer.