Please help. Auditors are arriving on Monday, and prior to his I would like clarification if this is HMDA reportable or not.

We've booked a loan, 6 mos. Primary repayment is refinance w/our r/e dept., Secondary Refinance with another mtg. lender. Purpose: Refinance existing 1st, and remodel expense.

Everything tells me YES this is HMDA. Except 6 months maturity is temporary financing. Our primary says refi with our r/e dept., the thing is we always broker out.

I've reported this on our HMDA LAR, and now I'm second guessing myself. Any thoughts?

Based on the information provided I cannot reason why this would not be temporary financing and thus excluded. 6 month term, loan not extinguished with payments, repayment is another loan. Not HMDA in my humble opinion

I agree that this is temporary financing and not subject to HMDA reporting. It's not the 6 month term that makes it temporary financing, however. It's the fact that this is an interim step to getting a more permanent financing situation in place. Search on "HMDA" and "Temporary" in these threads for more comprehensive discussion and tools.

Thanks to both of you for the reassurance and confidence booster. I've deleted this from our HMDA LAR, and re-read the section under A Guide to HMDA Reporting - Getting it Right.

I agree with both responses above.