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#1994302 - 02/06/15 08:44 PM To File or Not to File ???
Princess of Power Offline
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Princess of Power
Joined: Aug 2002
Posts: 406
Napa, CA
I am getting push back and need your opinions as to whether we need to file HMDA for CY 2014. I do not believe we need to file based on the definition of "Who Must Report" in the Guide to HMDA Reporting.
My review of potential HMDA loans in 2013 reveals that we originated 4 loans where the borrower owned the property (multi-family)free & clear. The purposes were varied, but NO proceeds were used to purchase any other R/E, but rather to reimburse themselves for improvements or other investment purposes.
I say we do not have to report for 2014 (but will in 2015 as we did originate in 2014 - 2 purchase $ loans 1-4, 1 purchase $ loan multi family and 1 refi of a purchase $ loan 1-4).
And the collective folks at BOL say?
Thanks

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#1994373 - 02/07/15 12:30 AM Re: To File or Not to File ??? Princess of Power
Princess of Power Offline
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Princess of Power
Joined: Aug 2002
Posts: 406
Napa, CA
No opinions?

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#1994404 - 02/08/15 08:56 PM Re: To File or Not to File ??? Princess of Power
Rocky P Offline
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Joined: Jun 2003
Posts: 7,379
Florida
2013 scenario = cash out refi - No HMDA

2014 scenario, do not understand. PoP, can you please write it out instead of abbreviating - "I say we do not have to report for 2014 (but will in 2015 as we did originate in 2014 - 2 purchase $ loans 1-4, 1 purchase $ loan multi family and 1 refi of a purchase $ loan 1-4)."
it is very tough to follow.
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#1994427 - 02/09/15 02:55 PM Re: To File or Not to File ??? Princess of Power
Truffle Royale Offline

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Joined: Jul 2003
Posts: 17,341
I think I understand your shorthand and I agree that you didn't have to report last year. But by March 1 of this year you do have to report the three purchase and one refi loans you did in 2014.

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#1994445 - 02/09/15 03:54 PM Re: To File or Not to File ??? Princess of Power
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,707
Bloomington, IN
They have no reporting responsibility for loans originated in 2014. These loans, made as of 12/31/14 (the preceding December 31st), makes them a covered institutions for loans they originate in 2015, reportable 3/1/16.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1994525 - 02/09/15 05:51 PM Re: To File or Not to File ??? Rocky P
Princess of Power Offline
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Princess of Power
Joined: Aug 2002
Posts: 406
Napa, CA
In other words:
Loans originated in 2013 due to purposes = NO HMDA reporting by 3/1/14
Loans originated in 2014 due to purposes = HMDA reporting for LOANS originated in 2015 by 3/1/16

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#1994530 - 02/09/15 06:02 PM Re: To File or Not to File ??? Princess of Power
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,707
Bloomington, IN
If you made no qualifying loans 2013 then you would not be a covered institution in 2014 therefore you would have no reporting requirements for the loans you originated in 2014.

The qualifying loans you made in 2014 qualifies you as a covered institution; and beginning on 1/1/15 you need to start collecting the applicable information for covered applications received on or after 1/1/15. This information will be placed on your LAR and reported on or before 3/1/16.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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