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#2149967 - 10/16/17 07:28 PM Purchase - Side Collateral?
Jace Offline
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Joined: Jul 2005
Posts: 21
We have a customer who is purchasing a residential condo. The thing is the main collateral is their IMA account, and we are also holding the primary residence as "side" or "abundance" of collateral. Since the primary residence has been included to some capacity does this make the transaction HMDA reportable for a purchase? Thank you.
Last edited by Jace; 10/16/17 07:30 PM.
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#2149968 - 10/16/17 07:31 PM Re: Purchase - Side Collateral? Jace
TMatt87 Offline
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TMatt87
Joined: May 2011
Posts: 1,932
Idaho
Taking the real estate as an "abundance of caution" doesn't exempt the loan from HMDA. It sounds like the purpose of the loan is to purchase a dwelling and will be secured by a dwelling, so it will be a HMDA reportable purchase.
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#2149988 - 10/16/17 08:24 PM Re: Purchase - Side Collateral? TMatt87
Jace Offline
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Joined: Jul 2005
Posts: 21
Great, that's what I thought as well but just need a second opinion.

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