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!
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Opinions expressed are my own and do not necessarily reflect those of my employer.