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#2189161 - 08/15/18 02:24 PM Modification to Add Rental house
NMB Offline
Gold Star
Joined: Jun 2002
Posts: 255
Southeast Michigan
I could use an opinion on how to treat this loan.

A loan was booked as unsecured. However, before the loan closed, a residence became known that we would like as security. So the loan was booked, unsecured, and two weeks later we added the collateral. No extension of maturity.

Normally collateral added during the term of the loan with no maturity extension would be considered a modification and not HMDA-reportable. But, since this one has the addition of the collateral noted in some correspondence before the loan closed, I am wondering if I should consider the loan secured and report it.

I have been flipping a coin on this one.
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#2189180 - 08/15/18 03:20 PM Re: Modification to Add Rental house NMB
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,227
Galveston, TX
Notes in the file are meaningless. Legal obligation only. If I was the borrower - it would tell you forget it after the fact.
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#2189181 - 08/15/18 03:20 PM Re: Modification to Add Rental house NMB
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,654
The Swamp
You closed and funded an unsecured loan. I would not report it until it refinances, if it does.
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My opinion only. Not legal advice.

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#2189195 - 08/15/18 03:36 PM Re: Modification to Add Rental house NMB
NMB Offline
Gold Star
Joined: Jun 2002
Posts: 255
Southeast Michigan
Thanks guys. I needed a little re-assurance on that one.
_________________________
My comments and opinions are my own, not my employer's.

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