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#2013078 - 05/08/15 06:54 PM Geocode on Refi with Partial Release
JessK Offline
100 Club
Joined: Jun 2010
Posts: 117
Louisiana
I am scrubbing our LAR and we have a refinance which is clearly HMDA. As part of the refi, they are releasing one of the dwellings.

Loan Operations geocoded the property and recorded that dwelling for reporting purposes. Is this ok to do? I am unable to find anything about partial releases in any of the guidance except for that it is a refinance. I am thinking that since this property was released, it is no longer securing the loan and therefore the property still securing the loan should be the reported geocode information.

Does anyone have any concrete guidance on this?

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#2013087 - 05/08/15 07:11 PM Re: Geocode on Refi with Partial Release JessK
NSF, CRCM Offline
Gold Star
NSF, CRCM
Joined: Apr 2013
Posts: 410
VA
Refer to the HMDA GIR Appendix D Paragraph 4(a)(9).

Here is the link to the guide.

http://www.ffiec.gov/hmda/pdf/2013guide.pdf
Last edited by NSFW; 05/08/15 07:16 PM. Reason: Added link
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The answers I give are my opinions. Not legal advice.

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#2013089 - 05/08/15 07:19 PM Re: Geocode on Refi with Partial Release JessK
complymuch, crcm Offline
Member
Joined: Apr 2013
Posts: 79
FL
Appendix A to Reg C states to enter the information to indicate the location of the property to which the loan relates. If the refi no longer relates to the released property, why would that property be geocoded?

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#2013102 - 05/08/15 07:40 PM Re: Geocode on Refi with Partial Release JessK
JessK Offline
100 Club
Joined: Jun 2010
Posts: 117
Louisiana
Thank you. That is exactly what I was thinking and I am happy to know now where to find the info. :-)

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