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#19886 - 06/06/02 07:13 PM HMDA
Anonymous
Unregistered

IF you do preapprovals and do not have an address for the property what do you put down for the census tract number.

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Lending Compliance
#19887 - 06/06/02 07:18 PM Re: HMDA
RVFlyboy Offline
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RVFlyboy
Joined: Oct 2000
Posts: 5,991
Soaring over Georgia
What do you put down where? If you're talking about on the HMDA LAR, you should not be reporting preapprovals on the HMDA LAR (at least not until 2004). Don't know where else you might be referring to documenting the census tract information.
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#19888 - 06/06/02 07:18 PM Re: HMDA
Anonymous
Unregistered

It is not necessary to report preapprovals (prequalifications) on HMDA. However, does anyone know how to report a withdrawn application that is missing the property address or the loan amount?

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#19889 - 06/06/02 07:46 PM Re: HMDA
Don_Narup Offline

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Joined: Jul 2001
Posts: 3,708
Las Vegas Nevada
To enter a record in the Feds HMDA annual submission software you must have a valid MSA (or NA) State and County FIPS code and Tract or BNA number. Otherwise you will get Validity Errors to correct before you can include the record in the annual submission report.

The loan amount must be greater than 0. If not you will get a validity error V250 "Loan Amount Not Greater Than 0"

If you do not have the information it won't be accepted for reporting, BUT you will get dinged if you don't report the withdrawn application especially if the applicant was of a minority race. Raises a flag that makess it look like you are holding out data.

In other words if you are using the FED HMDA data submission program you cannot enter the record unles you have all the information. If you don't have all the information you may get dinged for not having it.

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#19890 - 06/06/02 07:48 PM Re: HMDA
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
IMH(I)O - That's in my humble (ignorant) opinion -- An application without an address or one without a loan amount would not be considered a complete application eligible for the LAR.

Or am I missing something here?
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#19891 - 06/06/02 07:49 PM Re: HMDA
Bartman Offline
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Bartman
Joined: Oct 2000
Posts: 1,191
Springfield
If the customer hasn't provided a property address or a loan amount, it sounds like they're shopping for a house and they don't know a) where it will be or b) how much they qualify for. I'd call that a prequalification or preapproval, and I wouldn't report it on HMDA. If they later come in and withdraw that request, that doesn't change the prequalification status.
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#19892 - 06/06/02 07:57 PM Re: HMDA
DouglasFindling Offline
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DouglasFindling
Joined: Jun 2002
Posts: 1
New York, NY
Does your credit policy or loan procedures define what your bank considers an application(as you are allowed under 12 CFR 202.2(f))? If not you may want to consider doing so, it may help to resolve this type of issue in the future.

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#19893 - 06/06/02 08:00 PM Re: HMDA
Andy_Z Offline
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Andy_Z
Joined: Oct 2000
Posts: 27,750
On the Net
A mobile home loan may be submitted without a census tract and related data.

In the scenario above, these would be prequals and not reportable, as Jim noted. Come 2004 written commitments for these will be reportable and the rules will change.
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