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#2045104 - 10/20/15 02:17 PM HMDA
Levi B Offline
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Joined: Feb 2014
Posts: 4
In January my bank originated a closed end HMDA reportable loan on a truck for home improvement purposes, and now in October a change in terms was completed on the original loan extending some more funds to finish the home improvements. How should we report the new transaction?
Last edited by Levi B; 10/20/15 04:54 PM.
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HMDA

#2045105 - 10/20/15 02:22 PM Re: HMDA Levi B
raitchjay Offline
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Joined: Oct 2009
Posts: 9,381
OK
Modifications aren't reportable. Just for the record, a full-blown refinance of a non-dwelling secured HI loan wouldn't be reportable either.
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#2045159 - 10/20/15 04:21 PM Re: HMDA raitchjay
Adam F Offline
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Adam F
Joined: Apr 2013
Posts: 420
VA
Originally Posted By raitchjay
...a full-blown refinance of a non-dwelling secured HI loan wouldn't be reportable either.


I believe, however, if additional funds for home improvement were funded with the new request then it would be reportable.
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#2045173 - 10/20/15 05:02 PM Re: HMDA Levi B
Levi B Offline
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Joined: Feb 2014
Posts: 4
NSF home improvements will always take precedence over a refinance. So if you were to refinance a loan and the borrower was going to use some of the funds for home improvement then you would report the home improvement purpose of the loan.

Raitchjay why would you not report a modification? It seems odd, especially when you advance additional funds. You are now reporting less than was actually advanced to the customer.

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#2045186 - 10/20/15 05:41 PM Re: HMDA Levi B
raitchjay Offline
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Joined: Oct 2009
Posts: 9,381
OK
Why? Because the GIR says they aren't reportable.
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#2045210 - 10/20/15 06:29 PM Re: HMDA Levi B
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,765
Central City, NE
As raitchjay stated, HMDA says:
Modifications and Extensions … are not reportable as refinancings under Regulation C. [HMDA FAQ – Loan Purpose]

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