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#2086486 - 07/01/16 07:54 PM Report Reimbursements of Purch/Refi/Improvements?
Banker K, CRCM Offline
Gold Star
Joined: Jan 2010
Posts: 293
Oklahoma
Currently we do not report loans that are solely to reimburse the customer for the prior purchase, refi, or improvement of a dwelling (i.e. replenishing the customer's personal funds).

In 2018, however, there is the new loan purpose of "Other".

For consumer loans, would we now report these transactions with the purpose of "other"? It seems now that any consumer purpose loan secured by a dwelling is reported (unless temp financing, etc.). So it seems a reimbursement of funds would be report as "other".

For commercial loans, would we report these transactions with their original purpose? Or not report them at all? It seems now that you only report commercial purpose loans if secured by a dwelling and purpose is to purchase, refi, or improve (unless temp financing, etc.). So it seems a reimbursement of funds would not be reported on commercial purpose loans.

Thanks in advance for your thoughts on this. I will try to limit myself each week as I have a long list of "new HMDA" questions smile
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All comments are mine & should not be taken as legal advice.

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#2086490 - 07/01/16 08:19 PM Re: Report Reimbursements of Purch/Refi/Improvements? Banker K, CRCM
#12 Offline
Diamond Poster
Joined: Jun 2005
Posts: 1,343
consumer loans = any consumer purpose loan secured by a dwelling will be reportable. So if these reimbursement of funds transactions are for consumer purpose and secured by a dwelling, they will be reportable beginning in 2018.

Commercial loans = retain the current purpose test. So I would opine that a reimbursement of funds loan will remain not reportable in 2018 (no change from now).
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#2086536 - 07/05/16 01:32 PM Re: Report Reimbursements of Purch/Refi/Improvements? Banker K, CRCM
Banker K, CRCM Offline
Gold Star
Joined: Jan 2010
Posts: 293
Oklahoma
Thank you #12.
_________________________
Compliance - A Painful Addiction

All comments are mine & should not be taken as legal advice.

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#2086541 - 07/05/16 01:45 PM Re: Report Reimbursements of Purch/Refi/Improvements? Banker K, CRCM
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
Any dwelling secured consumer purpose loan will be reportable as of 1/1/2018.

If the loan is not a purchase,
No a refinance or cash out refinance (both must meet HMDA definition of refinance)
Not a home improvement loan
it is an "Other" loan.

Commercial loans must be for a purchase, refinance (HMDA definition) or home improvement. A non-refi cash out would not be reportable for commercial purpose loans.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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