For purposes of compliance with Appendix A to Subpart A of Part 365—Interagency Guidelines for Real Estate Lending Policies, how should one handle the reporting for the following situation:

2 loans secured by owner-occupied 1-4 family property (Loan A & Loan B) originated at the same time in 2010. Combined LTV = 100% so both loans were included in aggregate high LTV loan reporting.

Principal payments on the 2 loans have reduced the LTV to below 90%, therefore, the loans would no longer be required to be included in the aggregate high LTV reporting - however....

A third loan (Loan C) was originated in 2014 that was secured by the same property as the other two loans. When combining the outstanding balances of all three loans, the LTV was over 90%, therefore Loan C is added to the high LTV reporting.

The question is-
Do Loans A & B need to be added back to the high LTV reporting since the property they are secured by now has an LTV higher than 90% or can they remain excluded since the loans have been paid down to below 90% from their LTV at origination?

In determining the aggregate amount of such loans, institutions should: (a) Include all loans secured by the same property if any one of those loans exceeds the supervisory loan-to-value limits

Thanks Randy, that was my initial thought when I also saw that stipulation in the Guidelines and it makes sense since the risk on the first two loans increases with the third loan; I was second-guessing myself and I think was reading too much into the "origination" timing wording in the Guidelines:

"Loan-to-value or loan-to value ratio means the percentage or ratio that is derived at the time of loan origination by dividing an extension of credit by the total value of the property(ies) securing or being improved by the extension of credit plus the amount of any readily marketable collateral and other acceptable collateral that secures the extension of credit. "