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#201487 - 06/17/04 09:51 PM HMDA - Refi/Business
RFitzpatrick Offline
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RFitzpatrick
Joined: Apr 2002
Posts: 424
Pacific NW
If the bank committed to a small business loan that would have qualified as a refi under HMDA, but was withdrawn/not made, is it still reportable? If we hadn't committed?

I tend to think that it would still be a non reportable business loan until it is actually made and fits the refi criteria.
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#201488 - 06/17/04 09:58 PM Re: HMDA - Refi/Business
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,958
Bloomington, IN
This loan is reportable IMO. You report originations, denials, withdrawals and approves not accepted. Why would this not be reported as a withdrawal? The purpose of the loan no longer plays a part in the reportability of HMDA loans for refinances when the loan is dwelling secured.
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#201489 - 06/17/04 11:00 PM Re: HMDA - Refi/Business
RFitzpatrick Offline
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RFitzpatrick
Joined: Apr 2002
Posts: 424
Pacific NW
The regulation says we are to report all originations, declines, withdrawals, and loans approved not made for applications to purchase (no), improve (no), or refinance (maybe) residential property. The question is, was this an application for a refinancing? My initial response was based on the thought that this was an application for a business loan. Only during the credit evaluation did it become qualified as a refi when we requested additional collateral.
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#201490 - 06/18/04 12:56 AM Re: HMDA - Refi/Business
HRH Dawnie Offline
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HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
I wouldn't split hairs on it. You chose to offer a reportable product (HMDA). If you get too nit picky on it applying or not applying you're going to end up with confused lenders and grumpy examiners. Be conservative and report.

If I were auditing the file I'd give a hand slap for not reporting and then include it on the LAR personally...examiners probably wouldn't be that far off from my choice.
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#201491 - 06/18/04 04:35 AM Re: HMDA - Refi/Business
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,958
Bloomington, IN
Quote:

Only during the credit evaluation did it become qualified as a refi when we requested additional collateral.




It helps when the full details of the transaction is given. Your original question made it sound like the loan request was for the refinance of a business credit secured by a dwelling with the new loan being secured by a dwelling. i.e. " If the bank committed to a small business loan that would have qualified as a refi under HMDA, but was withdrawn/not made, is it still reportable? " In that case the loan is definitely reportable, as Dawnie said if you start splitting hairs, they'll be your hairs getting split by the examiners.

There was no mention in the original post this was a business credit request and you countered for the additional collateral. With this information then I would agree it would not be reportable.

BTW, you have a business loan denial, not a withdrawal. The applicant didn't accept your counter-offer.
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#201492 - 06/18/04 09:09 PM Re: HMDA - Refi/Business
HRH Dawnie Offline
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HRH Dawnie
Joined: Aug 2002
Posts: 7,353
Anchorage Alaska
I still would want to see a clean trail on this deal. How far did they get into the process before the client decided to back out? Did the home come into play as an option and the client immidately backed out, (didn't accept this option) or did it go further?

As Dan said, it's always easier to help when you have the full scope on the deal answers vary depending on little details
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CRA Rating is in...Oh who cares...I'm home with the baby.

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