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#2008455 - 04/16/15 03:10 PM
Reportable or not
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100 Club
Joined: Jul 2014
Posts: 194
MO
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I have a loan that is the 2nd DOT to finish the remodel on an I/P, and is a 6M term note. We have the 1st that is an LOC for the purchase and remodeling of the I/P, and it is a 6M term, and of course was not reported because it is a LOC. So, my question is would this new loan that is being used to finish the remodel be HMDA reportable? I don't think it would, but very unsure!
Thanks.
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#2008469 - 04/16/15 03:26 PM
Re: Reportable or not
Catm1991
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Power Poster
Joined: Oct 2009
Posts: 9,088
OK
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6M term note? 6 months? Interest only? If so, what are the plans for repayment? Refinance the loan at maturity into long term payments or something else?
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#2008521 - 04/16/15 05:36 PM
Re: Reportable or not
Catm1991
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10K Club
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
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We have the 1st that is an LOC for the purchase and remodeling of the I/P, and it is a 6M term, and of course was not reported because it is a LOC.
So you are saying you have a 6 month term note that is open-end credit?
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The opinions expressed are mine and they are not to be taken as legal advice.
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#2008587 - 04/16/15 07:11 PM
Re: Reportable or not
Catm1991
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10K Club
Joined: Dec 2000
Posts: 21,293
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#2008636 - 04/16/15 08:36 PM
Re: Reportable or not
Catm1991
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100 Club
Joined: Jul 2014
Posts: 194
MO
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It's not interest only, it's just the customer needed more money so we are taking a 2nd on the I/P property. I am pretty sure it's not reportable. The loan officer states, and the file shows, the intentions of the customer are unknown at this point, so with it being short term and the other factors I think it's not going to be reportable.
Thanks.
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#2008647 - 04/16/15 08:56 PM
Re: Reportable or not
Catm1991
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Power Poster
Joined: Oct 2009
Posts: 9,088
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The 2nd lien loan is fully (or partially) amortizing? Is it an open-end or closed-end loan?
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#2008655 - 04/16/15 09:12 PM
Re: Reportable or not
Catm1991
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100 Club
Joined: Jul 2014
Posts: 194
MO
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I/P is investment property, and 6M is 6 months, sorry. And closed-end loan.
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#2008783 - 04/17/15 04:51 PM
Re: Reportable or not
Catm1991
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10K Club
Joined: Nov 2000
Posts: 18,762
Central City, NE
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The loan officer states, and the file shows, the intentions of the customer are unknown at this point, so with it being short term and the other factors I think it's not going to be reportable. Short term improvement IS reportable. It's not temporary (replaced by a 2nd phase loan). Why do you think it's not reportable?
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#2009809 - 04/23/15 05:10 PM
Re: Reportable or not
Catm1991
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100 Club
Joined: Jul 2014
Posts: 194
MO
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I am new to HMDA and was trained that we do not report loans that are short term, being less than 12 month, but with the research and the 1st training they have sent me to I....think it might, but told it wouldn't be, so I'm unsure??
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#2009826 - 04/23/15 05:42 PM
Re: Reportable or not
Catm1991
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Power Poster
Joined: Oct 2009
Posts: 9,088
OK
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We need to know what the plan for repayment is: refinance into long-term financing or simply pay the loan off at maturity. If the loan is designed to be replaced by financing of a much longer term, then it's temporary and not reportable. If the loan is designed with the idea of your borrower paying the loan off in cash at maturity, it's simply a short term loan that would be reportable.
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#2009843 - 04/23/15 06:33 PM
Re: Reportable or not
Catm1991
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Power Poster
Joined: Oct 2009
Posts: 9,088
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David, i'm just concerned that Catm might be using the term "short term" simply because the loan term is, well, short....IOW, it might actually be temporary financing and she is calling it "short term".
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