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#1833547 - 07/17/13 01:52 PM
Re: HMDA - Portfolio Simo Mortgage Loan
DNana
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Junior Member
Joined: Nov 2010
Posts: 41
TN
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Kathleen, We are obtaining the GMI but the question the following:
"Can the portfolio lender use the GMI from the mortgage application since for the portfolio lender usually does not see the applicant?"
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Nana, CRCM
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#1833603 - 07/17/13 03:05 PM
Re: HMDA - Portfolio Simo Mortgage Loan
DNana
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10K Club
Joined: Aug 2002
Posts: 47,530
Bloomington, IN
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They generally don't see the applicant in mail or Internet applications either yet if the GMI is complete they report it.
The portfolio loan officer and your secondary loan officer are both employees of the bank. The bank can use the information for both loans when an applicant applies for a first and second simultaneously.
I'm kind of curious though, if they applied simultaneously for both loans why aren't the loans closed simultaneously?
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The opinions expressed are mine and they are not to be taken as legal advice.
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#2015024 - 05/19/15 07:01 PM
Re: HMDA - Portfolio Simo Mortgage Loan
DNana
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Power Poster
Joined: Oct 2009
Posts: 9,104
OK
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I think by definition if someone applies for a 100% purchase loan, they are (whether they're aware or not) submitting 2 applications (one for the 80% purchase; the other for the 20% purchase). Your bank is/was considering making the loan(s), but only as 2 separate loans right? If it falls through, i'd report it as 2 separate applications--because that's how your bank was treating it. Otherwise, you wouldn't have been contemplating the 2nd lien loan simultaneously.
Last edited by raitchjay; 05/19/15 07:09 PM.
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#2015049 - 05/19/15 08:02 PM
Re: HMDA - Portfolio Simo Mortgage Loan
DNana
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Power Poster
Joined: Oct 2009
Posts: 9,104
OK
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I do agree that it's all in how the bank is treating it, but it sounds like the bank (correct me if i'm wrong) is ONLY considering making 100% loan via 2 loans (are there banks that will make only 1 loan to finance 100% of the purchase price of a home?); therefore, they treated the application in that manner. If not, i guess i would assume you'd deny the application right away. If the 2 loans were going to happen (you approved them), and they later "withdrew" (approved, not accepted), would you still only report 1 LAR entry?
I'm with David on this...i'm not trying to make a definitive statement; just stating my opinion on something that, to be honest, i rarely see in my shop.
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#2015069 - 05/19/15 08:53 PM
Re: HMDA - Portfolio Simo Mortgage Loan
David Dickinson
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Power Poster
Joined: Oct 2009
Posts: 9,104
OK
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I think once the lender approves the request but breaks it into 2 to do so, the result is 2 LAR entries no matter what happens.
if the request is denied initially, I think you would have 1 denial on the LAR.
Thoughts?
David, i'm in agreement with that.
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#2015071 - 05/19/15 08:56 PM
Re: HMDA - Portfolio Simo Mortgage Loan
DNana
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Power Poster
Joined: Oct 2009
Posts: 9,104
OK
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Although (as you say, just thinking out loud), i'm wondering if i'd say it even had to be "approved"...i'm thinking once the bank breaks it into 2 pieces to consider approval, it's reportable as 2 LAR entries. If they want to deny it outright from the beginning because they know they don't want to make a 100% loan (or loans), then one LAR entry. I'm willing to listen to disagreement though.
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