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#2174385 - 04/19/18 11:11 PM 2nd Mortgage on Rental
jlroberts Offline
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jlroberts
Joined: Sep 2009
Posts: 1,601
Ohio
Customer doing a 2nd mortgage on one of his rental properties. Purpose of funds is to buy a Pizza Shop.
HMDA reportable as a Purchase or Other - Buy Pizza Shop?

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#2174386 - 04/19/18 11:13 PM Re: 2nd Mortgage on Rental jlroberts
TMatt87 Offline
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TMatt87
Joined: May 2011
Posts: 1,987
Idaho
It sounds like a commercial loan, so the other category doesn't apply. There is no purchase because the funds won't be used to purchase a dwelling, and it doesn't sounds like a refi or home improvement would apply based on the limited info, so I would say not HMDA reportable.
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#2174387 - 04/19/18 11:16 PM Re: 2nd Mortgage on Rental jlroberts
jlroberts Offline
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jlroberts
Joined: Sep 2009
Posts: 1,601
Ohio
That where I was leaning but I keep getting hung up on the collateral being a dwelling. Need to focus on purpose of funds. Thanks!

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#2174475 - 04/20/18 04:27 PM Re: 2nd Mortgage on Rental jlroberts
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Business purpose home equity loans are not reportable, unless the proceeds are used to purchase, refinance or improve a dwelling. As TMatt stated, this loan is not subject to HMDA.
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#2175990 - 05/01/18 12:54 PM Re: 2nd Mortgage on Rental jlroberts
Compliance NABW Offline
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Joined: Oct 2015
Posts: 1,669
Purpose and collateral both come into play in HMDA. An easy way to remember how to report these situations is that if the Purpose field would result in using "Other" and funds are not used for a consumer reason, then you do not report it.

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