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#2185454 - 07/16/18 02:43 PM Funds / Vacation and Minor Repairs to dwelling
Cat Lover Offline
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This is a loan prior to January 1, 2018, personal loan secured by a vehicle to payoff debt and minor home improvements. Should that have been disclosed as Home Improvement and back in 2017 reported in HMDA?

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#2185458 - 07/16/18 02:45 PM Re: Funds / Vacation and Minor Repairs to dwelling Cat Lover
raitchjay Offline
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OK
Did your bank classify and report non-dwelling secured HI loans then?
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#2185459 - 07/16/18 02:46 PM Re: Funds / Vacation and Minor Repairs to dwelling Cat Lover
Cat Lover Offline
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Joined: Jun 2016
Posts: 147
Yes

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#2185460 - 07/16/18 02:47 PM Re: Funds / Vacation and Minor Repairs to dwelling Cat Lover
raitchjay Offline
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OK
Then unless it was exempt as temporary financing, it sounds like you should have reported it (and classified it as such).
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#2185462 - 07/16/18 02:49 PM Re: Funds / Vacation and Minor Repairs to dwelling Cat Lover
Adam Witmer Offline
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The key in this is "classified it as (a home improvement)" loan. I agree with raitchjay.
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#2185463 - 07/16/18 02:55 PM Re: Funds / Vacation and Minor Repairs to dwelling Cat Lover
Cat Lover Offline
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Classified as non-dwelling secured and not a temporary financing.

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#2185465 - 07/16/18 03:05 PM Re: Funds / Vacation and Minor Repairs to dwelling Cat Lover
RR Joker Offline
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The Swamp
Notified to move post to HMDA forum.
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#2185471 - 07/16/18 03:20 PM Re: Funds / Vacation and Minor Repairs to dwelling Cat Lover
Adam Witmer Offline
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Originally Posted By Cat Lover
Classified as non-dwelling secured and not a temporary financing.

Just to clarify, did you also "classify" it as a HI loan?

From the old GIR:
"Classification requirement for loans not secured by a lien on a dwelling. An institution has “classified” a loan that is not secured by a lien on a dwelling as a home improvement loan if it has entered the loan on its books as a home improvement loan, or has otherwise coded or identified the loan as a home improvement loan. For example, an institution that has booked a loan or reported
it on a “call report” as a home improvement loan has classified it as a home improvement loan. An institution may also classify loans as home improvement loans in other ways (for example, by color-coding loan files)."
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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