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#2063747 - 02/10/16 11:37 PM Commercial Line of Credit
nikki_compliance Offline
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Joined: Mar 2010
Posts: 520
NM
Is a refinance of a commercial line of credit secured by rental properties HMDA reportable
Last edited by nikki_compliance; 02/10/16 11:40 PM.
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#2063748 - 02/11/16 12:26 AM Re: Commercial Line of Credit nikki_compliance
hmdagal Online
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hmdagal
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Posts: 3,841
If the line of credit is satisfied and the borrower is the same on both the line of credit and the new loan, then yes.

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#2063750 - 02/11/16 12:47 AM Re: Commercial Line of Credit nikki_compliance
JC (Darth HMDA) Offline
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Joined: Dec 2013
Posts: 1,399
CA
Make sure the line if being paid OFF (not DOWN and kept open).

If you are replacing an existing lien secured by the rental with a new lien, and both loans are to the same borrower(s) you have a HMDA reportable action.

hooray!
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#2063868 - 02/11/16 04:34 PM Re: Commercial Line of Credit nikki_compliance
nikki_compliance Offline
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Joined: Mar 2010
Posts: 520
NM
What if the LOC is still open just renewing because it has matured? Still HMDA?

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#2063870 - 02/11/16 04:38 PM Re: Commercial Line of Credit nikki_compliance
raitchjay Online
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Joined: Oct 2009
Posts: 9,086
OK
You'd have to define "renewal". Also, is it being refinanced into another open-end LOC, or refinanced into a closed-end loan? If the former, reporting is optional (based on whether you choose to report your open-end LOCs or not). If the latter, it would be reportable (with the caveats about same borrower mentioned above). If by "renewal" you just mean a modification/extension, then no, not reportable.
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#2063872 - 02/11/16 04:41 PM Re: Commercial Line of Credit nikki_compliance
nikki_compliance Offline
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Joined: Mar 2010
Posts: 520
NM
So in terms of renewal it would be a refi to another open end loc.... so not reportable correct?

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#2063873 - 02/11/16 04:43 PM Re: Commercial Line of Credit nikki_compliance
raitchjay Online
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Joined: Oct 2009
Posts: 9,086
OK
If you don't report open-end LOCs, correct.
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