Loan application to consolidate two dwelling secured notes and cash out funds for the purpose of constructing a taj-mahal shed on vacant land adjacent to the dwelling. The appraisal did not come in high enough so the loan was adjusted to include the vacant land parcel. My concern is that this should have been a turndown of the application on the original terms and a counteroffer to add the additional collateral?

What do you all think?

Then as far as HMDA reportability, this would not be considered home improvement because the shed is being constructed on vacant land adjacent to the parcel in which the primary dwelling is one, correct?

consolidate two dwelling secured notes


Sounds like a refinance to me, the purpose of the additional cash out is not pertinent as it is not home improvement.

My concern is that this should have been a turndown of the application on the original terms and a counteroffer to add the additional collateral?

The appraisal did not come in high enough so the loan was adjusted to include the vacant land parcel.

Appears to me there was a counteroffer made and accepted. Otherwise why was the additional parcel added?

Reg. B does not require a counteroffer be in writing.

Thank you both, I appreciate and value your opinions!