I need some clarifications on reporting assumptions.
1) Is it correct that the Reg Z definition of assumption does not carry over to HMDA?
2) Is it true that the addition or deletion of a borrower to/from a loan is not an assumption if one of the original borrowers remains on the loan. (I am not considering guarantors in this situation.)
3) If a new borrower completely replaces the original borrower(s) it is an assumption. If the new borrower obtains title when taking over the loan its purpose is home purchase. How do we assign purpose if the new borrower is in title before assuming the loan? If the original purpose was not a purchase would the original purpose continue on? If the original purpose was purchase, would the new purpose be Home Equity?

Any thoughts on assumptions?

Reviving this thread on assumptions, since I have similar questions. We have a son assuming the loan from the father.

- Disclosures - Is the assumption a new loan and therefore TRID applies?
- HMDA - Do we report the transaction as a purchase?

Thanks!

It depends how the assumption is being processed.

For Reg. Z see 1026.20(b). Most likely the transaction will be a RMT for the son requiring disclosures.

For HMDA see page 12 of the 2018 GIR.