Thread Options
#2039797 - 09/22/15 01:19 PM HMDA Multiple borrowers
LMP Offline
Member
Joined: Sep 2011
Posts: 74
How are multiple borrowers treated for HMDA and where can I find information addressing this.

Return to Top
HMDA

   
HMDA Academy
#2039800 - 09/22/15 01:21 PM Re: HMDA Multiple borrowers LMP
Skittles Offline
10K Club
Skittles
Joined: Sep 2002
Posts: 13,963
TN
Could you explain a little more what you're looking for, please? I don't quite understand what you mean by 'treated'.
_________________________
My Opinions Only

Return to Top
#2039808 - 09/22/15 01:51 PM Re: HMDA Multiple borrowers Skittles
LMP Offline
Member
Joined: Sep 2011
Posts: 74
If I have 4 borrowers on one mortgage how many are required to be on the HMDA LAR

Return to Top
#2039813 - 09/22/15 01:56 PM Re: HMDA Multiple borrowers LMP
Skittles Offline
10K Club
Skittles
Joined: Sep 2002
Posts: 13,963
TN
Only two; however you must collect the monitoring information from all 4.
_________________________
My Opinions Only

Return to Top
#2039816 - 09/22/15 01:57 PM Re: HMDA Multiple borrowers LMP
hmdagal Offline
Power Poster
hmdagal
Joined: Dec 2002
Posts: 3,816
Remember that it's the application that is reported on the LAR, not the borrowers. With that being said, if there are more than 2 applicants, you would collect GMI for all of them, and report the information for the first 2 on your LAR. Income should be reported for all applicants.

Return to Top
#2039830 - 09/22/15 02:20 PM Re: HMDA Multiple borrowers LMP
Rocky P Online
Power Poster
Joined: Jun 2003
Posts: 7,354
Florida
From HMDA GIR

c. If there is more than one co-applicant, provide the required information only for the first co-applicant listed on the application form. If there are no co-applicants or coborrowers, use Code 5 (for ethnicity) and Code 8 (for race) for “no co-applicant” in the coapplicant column.
_________________________
Integrity. With it, nothing else matters. Without it, nothing else matters.

Return to Top
#2039850 - 09/22/15 03:06 PM Re: HMDA Multiple borrowers LMP
LMP Offline
Member
Joined: Sep 2011
Posts: 74
Thanks everyone

Return to Top
#2053765 - 12/11/15 04:24 PM Re: HMDA Multiple borrowers LMP
Frank Ernest Offline
100 Club
Joined: Nov 2004
Posts: 138
Somewhere on a beach
How would you report the monitoring for a joint application that was originally denied, then re-opened after removing one of the applicants, and was again denied? An adverse action was sent to both applicants originally, and again to the single applicant. Would you report monitoring for both applicants, or only the single applicant from the final action?

Return to Top
#2053775 - 12/11/15 04:47 PM Re: HMDA Multiple borrowers LMP
burke116 Offline
Platinum Poster
Joined: Jun 2014
Posts: 536
RVA
That's a new application and should be a separate LAR entry.

Return to Top
#2053948 - 12/14/15 02:30 PM Re: HMDA Multiple borrowers burke116
Frank Ernest Offline
100 Club
Joined: Nov 2004
Posts: 138
Somewhere on a beach
Does anyone agree that it should be two separate applications, even though only one application was entered?

Return to Top
#2053990 - 12/14/15 04:15 PM Re: HMDA Multiple borrowers LMP
Dan Persfull Online
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,631
Bloomington, IN
How would you report the monitoring for a joint application that was originally denied, then re-opened after removing one of the applicants, and was again denied?

Did you treat them as separate applications or did you treat the second application as a continuation of the original application? See page D-7 of the GIR.

FWIW we use to treat these as one application but for tracking purposes we now treat them as separate applications and report both.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

Return to Top
#2054070 - 12/14/15 08:12 PM Re: HMDA Multiple borrowers Dan Persfull
Frank Ernest Offline
100 Club
Joined: Nov 2004
Posts: 138
Somewhere on a beach
We treated the second application as a continuation of the original application. We are reporting the monitoring for both applicants as they originally applied jointly. Thanks Dan for your response.

Return to Top

Moderator:  SMQ, CRCM