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#2117216 - 02/07/17 12:58 AM Commercial Loan - Multiple Properties
run4fun Offline
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Joined: Mar 2002
Posts: 98
Just wanting to check myself for commercial loans secured by multiple properties. We report each property on a separate line of our LAR for both purchase and refinance loans. Is it acceptable to report refinance loans on multiple lines when we do not know the original purpose of the loan being refinanced (e.g., a refinance from another institution)? I'm getting tripped up by language in the GIR "Property location - multiple properties (home purchase/refinance of home purchase)".

Thanks!

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#2117226 - 02/07/17 01:35 PM Re: Commercial Loan - Multiple Properties run4fun
Dan Persfull Offline
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Dan Persfull
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Bloomington, IN
The part you are getting tripped up on is the section that outlines the coverage requirements for a financial institution.

When it comes to a reportable refinancing the purpose of the original loan has no bearing. If the new loan is dwelling secured and it is satisfying an existing dwelling secured loan to the same borrower it is a reportable refinancing.
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#2117399 - 02/08/17 05:35 AM Re: Commercial Loan - Multiple Properties Dan Persfull
run4fun Offline
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Joined: Mar 2002
Posts: 98
Thanks, Dan. So I would read the first section here ("home improvement loans and r eminences of home improvement loans") the same way - as being associated with the coverage clarification? I suspect the person challenging me (and causing me to doubt myself) is going to focus on the "refinance of home improvement " and "refinance of home purchase" while disregarding the clear definition of a refinance for reporting purposes. To be clear, we do not know the purpose of the loan being refinanced, but we do report the multiple properties as separate LAR line items.

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#2117484 - 02/08/17 05:23 PM Re: Commercial Loan - Multiple Properties run4fun
David Dickinson Offline
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David Dickinson
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Central City, NE
Side note: In 2018, you will only use 1 LAR entry per application. Multiple entries will no longer be accepted. Instead, you'll pick 1 property and use it consistently for all entries.
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#2139923 - 07/28/17 02:36 PM Re: Commercial Loan - Multiple Properties run4fun
NorthSouth Offline
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Joined: Jun 2015
Posts: 26
Reviving this thread, we're currently discussing multiple dwellings as collateral. Using an example of a commercial loan secured by three dwellings that's being refinanced with no new funds - anyone care to share how you're selecting which property to report? Census tract, value, other?
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#2139942 - 07/28/17 03:12 PM Re: Commercial Loan - Multiple Properties run4fun
Skittles Online
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TN
We use the first property disclosed on the note. No reason - except to be consistent.
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#2139953 - 07/28/17 03:32 PM Re: Commercial Loan - Multiple Properties run4fun
NorthSouth Offline
Junior Member
Joined: Jun 2015
Posts: 26
Thanks Skittles, that seems to be what we currently do. Our CRA officer would like to consistently use the property in a low-to-mod census tract, if there is one. I'm struggling with that a little if the other properties are the majority of the collateral.
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