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#2176775 - 05/04/18 07:16 PM HMDA and MECA
angela aniol Offline
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Joined: Nov 2017
Posts: 48
I recently heard of an exemption for MECA loans for HMDA, however, I cannot find out what this is. I believe it is regarding loan extensions or modifications and whether or not they are reportable. Can anyone provide some information?

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#2176800 - 05/04/18 07:47 PM Re: HMDA and MECA angela aniol
John Burnett Offline
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John Burnett
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Posts: 40,086
Cape Cod
I wonder if you are referring to the 2017 amendments that made some Reg CC changes relating to New York State consolidation, extension, and modification agreements (CEMA).
Last edited by John Burnett; 05/04/18 07:51 PM.
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#2176802 - 05/04/18 07:50 PM Re: HMDA and MECA angela aniol
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
If so, go to section 1003.2 in our Reg C regs pages, at https://www.bankersonline.com/regulations/12-1003-002, and do a "find-in-page" for "New York" You'll find 11 matches, all in the Commentary to 1003.2.
Last edited by John Burnett; 05/04/18 07:59 PM. Reason: corrected citation. It must be Friday afternoon.
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#2184075 - 07/03/18 10:19 PM Re: HMDA and MECA angela aniol
angela aniol Offline
Junior Member
Joined: Nov 2017
Posts: 48
I am not referring to a New York CEMA. But I did find this from Jerod Moyer from a 2005 Bankersonline forum.

The question is did you "satisfy and replace". If you have loan A (dwelling secured) and then make loan B (dwelling secured) which "satisfies and replaces" Loan A it's reportable as a refinance.

The following is from the section by section analysis:

MECAs. The Board did not propose any change regarding the status of modification, extension, and consolidation agreements (MECAs). MECAs are not reported because they do not meet the definition of a refinancing (satisfaction and replacement of an existing mortgage loan). A few commenters asserted, however, that MECAs should be reported because they substitute for traditional refinancings in some states, such as New York and Texas, to avoid mortgage recording fees and taxes.

The final rule does not include MECAs as reportable under HMDA. The existing definition of a refinancing establishes a bright-line test for reportable transactions. The Board believes that MECA data may be useful in certain instances, but that, under the existing loan classification scheme, the advantages of a bright- line test for determining whether a transaction should be reported�especially in reducing compliance burden� outweigh the benefits of additional data on these transactions. Therefore, the Board has not revised the definition of refinancing to include MECAs.

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