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#2154535 - 11/22/17 01:49 PM Renewal path changed to Refinance
Likes to Comply Offline
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Joined: Nov 2008
Posts: 1,055
In the mountains
If a customer applies to renew their loan (true renewal - note would not replace and extinguish previous note) but for some reason during the loan process it is determined that instead this loan must be refinanced (a covered loan for HMDA) must we at that point try to obtain the Demographic Information from the applicant?
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#2154591 - 11/22/17 03:38 PM Re: Renewal path changed to Refinance Likes to Comply
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,765
Bloomington, IN
Once it becomes a covered loan you must comply with the applicable regulations.
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#2154643 - 11/22/17 05:43 PM Re: Renewal path changed to Refinance Likes to Comply
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I agree. In a sense, you have a new application - a new request. Not that you need to complete a new application form, but rather the request has changed. At the point this happens, it became subject to HMDA. Document the date and what happened (tell the story).
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#2154681 - 11/22/17 08:37 PM Re: Renewal path changed to Refinance Likes to Comply
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Diamond Poster
Joined: Nov 2008
Posts: 1,055
In the mountains
Thanks!!!
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#2154841 - 11/27/17 05:29 PM Re: Renewal path changed to Refinance Likes to Comply
Banker K, CRCM Offline
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Joined: Jan 2010
Posts: 290
Oklahoma
When we are faced with these situations (oh yeah, here too...) our procedure is to have the very first application form in file and stamp "initial" at top right, then print a revised application (noting what changed - ex: purpose) with the date of that revision and then any applicable disclosure docs (ex: the GMI) would be dated with that date as well.

Our overall loan application date would be the earlier date.
However, based on my understanding, for Reg C HMDA reporting, the app date on the LAR would be the date it actually turned into a HMDA application.
Any thoughts on that???
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#2154895 - 11/27/17 07:58 PM Re: Renewal path changed to Refinance Likes to Comply
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
. . .the app date on the LAR would be the date it actually turned into a HMDA application."
Agree. It's not a HMDA application until it becomes subject to HMDA. For example, I might get prequalified last month, but don't have a house picked out. You have a Reg B app, but not a HMDA app at this time. Assume I find a house today and call with the address. Today you have a HMDA application. Document this and record it on the LAR with an application of today (not last month).
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David Dickinson
http://www.bankerscompliance.com

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