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?
#2185471 - 07/16/1803:20 PMRe: Funds / Vacation and Minor Repairs to dwelling Cat Lover
Adam Witmer
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Joined: Sep 2010
Posts: 2,658
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
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