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#2017728 - 06/02/15 07:26 PM HMDA-What Amount To Report
Love Cruising Offline
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Joined: Mar 2009
Posts: 248
Customer applied for 550,000 and disclosures were issued, a week later the bank was able to approve him for a higher amount of 565,000 and new disclosures were issued. the bank extended the approval letter for $565,000. Customer found a better rate and withdraw the request. For HMDA purposes, do I report the loan amount as $565 or for the original amount applied of $550?

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#2017731 - 06/02/15 07:30 PM Re: HMDA-What Amount To Report Love Cruising
NSF, CRCM Offline
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NSF, CRCM
Joined: Apr 2013
Posts: 410
VA
We would report the $565k.

To me its the same as the following:

Customer applies for $100k loan. Appraisal comes in lower than expected so bank counteroffers to do loan for $90k. If the customer accepts and closes the loan at $90k. You wouldn't report $100k, you would report $90k.

The final amount would be reported.
Last edited by NSFW; 06/02/15 07:31 PM. Reason: Added comment
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#2017740 - 06/02/15 07:37 PM Re: HMDA-What Amount To Report Love Cruising
hmdagal Online
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hmdagal
Joined: Dec 2002
Posts: 3,812
Did the customer request the higher loan amount? If so, that's what I would report.

If the bank increased the amount, I would report the amount of the original request.

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#2017761 - 06/02/15 08:28 PM Re: HMDA-What Amount To Report Love Cruising
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,418
Bloomington, IN
Customer applies for $100k loan. Appraisal comes in lower than expected so bank counteroffers to do loan for $90k. If the customer accepts and closes the loan at $90k. You wouldn't report $100k, you would report $90k.

But if they don't accept you would report the $100K.


It appears the bank was able to offer the applicant additional money based on their underwriting. It does not appear by the information provided the applicant amended the loan amount. The applicant did not accept the counteroffer for a larger loan amount therefore the original amount applied for, in this case $550K, would be reported.
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#2017776 - 06/02/15 08:41 PM Re: HMDA-What Amount To Report Love Cruising
Love Cruising Offline
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Joined: Mar 2009
Posts: 248
By what the officer tells me, the borrower was not sure the appraisal would come for a higher amount, but in actuality he did want the higher loan amount. So would we report the higher $565?

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#2017782 - 06/02/15 08:46 PM Re: HMDA-What Amount To Report Love Cruising
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,418
Bloomington, IN
The original loan request was for $550K therefore the answer depends if the applicant requested the higher loan amount or if the bank countered the higher loan amount.

See hmadagal's response.
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The opinions expressed are mine and they are not to be taken as legal advice.

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