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#2014147 - 05/14/15 06:43 PM Down Payment Assistance Programs
Mel in WA Offline
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Joined: Mar 2013
Posts: 1,129
Are concurrent second lien loans for down payment assistance on the first lien transaction HMDA reportable?

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#2014151 - 05/14/15 06:53 PM Re: Down Payment Assistance Programs Mel in WA
NSF, CRCM Offline
Gold Star
Joined: Apr 2013
Posts: 410
From Regulation C Commentary: [You can also find this in the GIR]

6. Second mortgages that finance the downpayments on first mortgages. If an institution making a first mortgage loan to a home purchaser also makes a second mortgage loan to the same purchaser to finance part or all of the home purchaser's downpayment, the institution reports each loan separately as a home purchase loan.
Last edited by NSFW; 05/14/15 06:55 PM. Reason: Added comment
It is better to act cautiously beforehand than to suffer afterward.

The answers I give are my opinions. Not legal advice.

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#2014585 - 05/18/15 12:36 PM Re: Down Payment Assistance Programs NSF, CRCM
TINKerBell Offline
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Joined: Nov 2006
Posts: 3,231
Tiger's Den!
Further clarification please. If the loan is a down payment assistance program loan, such as MSHDA, we wouldn't report that as a separate purchase since the state of Michigan underwrote the loan. Correct?
The last thing that blew my mind was the wind.

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#2014586 - 05/18/15 01:05 PM Re: Down Payment Assistance Programs Mel in WA
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
That is going to depend upon individual circumstances. Did the bank underwrite and approve the actual loan to the borrower while the state approved the loan to qualify under its program?

If the bank does not underwrite the transaction and simply originates if the state approved the transaction (given that the bank has already approved the larger purchase loan), then the bank will not report the loan on the HMDA LAR.
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy

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#2205528 - 02/08/19 07:43 PM Re: Down Payment Assistance Programs Mel in WA
Hales53 Offline
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Joined: Mar 2017
Posts: 23
So then Kathleen, no one would report the transaction?

Thank you!

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#2205583 - 02/10/19 03:59 PM Re: Down Payment Assistance Programs Mel in WA
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
That's certainly possible. That's true of many financial institutions not subject to HMDA.
David Dickinson

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