Skip to content
BOL Conferences
Thread Options
#2171644 - 04/03/18 08:51 PM Statement of Applicant
George Offline
Gold Star
Joined: Apr 2016
Posts: 364
Does this still apply to 2018 HMDA as far as purpose goes?

If so, then would you interpret this statement "refinancing plus cash out for new investment opportunities" as real estate specific? Thus, reporting the loan as a purchase? Or is that statement too general?

Return to Top
HMDA

   
HMDA Academy
#2171647 - 04/03/18 09:05 PM Re: Statement of Applicant George
TMatt87 Offline
Diamond Poster
TMatt87
Joined: May 2011
Posts: 1,987
Idaho
IMO, that statement is too general. Investment opportunities could mean a lot of different things. I would report as a refinance.
_________________________
All opinions are my own, not my employer's

Return to Top
#2171654 - 04/03/18 09:25 PM Re: Statement of Applicant George
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I would ask for clarity and document it, rather than make assumptions.
_________________________
David Dickinson
http://www.bankerscompliance.com

Return to Top
#2171656 - 04/03/18 09:31 PM Re: Statement of Applicant George
George Offline
Gold Star
Joined: Apr 2016
Posts: 364
Will do. So then, the statement of applicant does still apply.

Thank you Matt, Thank you David!

Return to Top
#2171670 - 04/03/18 10:43 PM Re: Statement of Applicant George
David Dickinson Offline
10K Club
David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
This is from the 2018 rules:
A financial institution may rely on the oral or written statement of an applicant regarding the proposed use (purpose) of covered loan proceeds. [Commentary to §1003.4(a)(3) #1]
_________________________
David Dickinson
http://www.bankerscompliance.com

Return to Top

Moderator:  SMQ, CRCM