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#2195428 - 10/15/18 06:02 PM Abundance of Caution
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Would you include property that was taken as an abundance of Caution for Property Value and # of units when reporting HMDA data?

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#2195433 - 10/15/18 06:26 PM Re: Abundance of Caution Compliance Newbie
RR Joker Offline
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Yep. If you have an used the value. Units would count regardless.
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#2195437 - 10/15/18 06:36 PM Re: Abundance of Caution Compliance Newbie
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What if they didn't use it's value in their CLTV?

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#2195440 - 10/15/18 06:45 PM Re: Abundance of Caution Compliance Newbie
RR Joker Offline
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If they don't use a value, you don't report the value. You only report what was considered in making the credit decision. However, that has no bearing on how many dwellings you have wink
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#2195442 - 10/15/18 06:51 PM Re: Abundance of Caution Compliance Newbie
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Thanks RR Joker.

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#2196125 - 10/22/18 08:29 PM Re: Abundance of Caution Compliance Newbie
rxg217 Offline
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If a loan is secured by a non-dwelling as the primary collateral and a residential dwelling as an abundance of caution, is that HMDA reportable? If yes, does your answer change is the proceeds for the loan are not related to a consumer purpose?

Fair Warning: I am fairly new to banking and commercial/consumer lending, so I apologize in advance if my questions don't make complete sense. My background is with non-bank lenders that were 100% residential mortgage shops, so these commercial/consumer nuances are throwing me for a loop.

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#2196127 - 10/22/18 08:35 PM Re: Abundance of Caution Compliance Newbie
Skittles Online
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What is the purpose of the loan?
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#2196135 - 10/22/18 09:23 PM Re: Abundance of Caution Compliance Newbie
rxg217 Offline
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That is what I don't know how to answer. These loans are out of our SBA division and the funds are typically used to either consolidate existing debt, acquire commercial property, or purchase inventory.

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#2196139 - 10/22/18 09:46 PM Re: Abundance of Caution rxg217
crcmnot Offline
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SBA normally takes everything including the kitchen sink on their loans...which includes the borrower's/guarantor's principal residence. In my experience, they are collateral only and not for a purchase, refi or home improvement of that residence or any residence securing the SBA loan....so, not HMDA reportable, if that is the case.

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#2196157 - 10/23/18 11:49 AM Re: Abundance of Caution Compliance Newbie
Skittles Online
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I agree with crcmnot. There is no 'other' purpose for commercial/business loans.
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#2196256 - 10/23/18 08:42 PM Re: Abundance of Caution Compliance Newbie
rxg217 Offline
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Great, thank you, Skittles and crcmnot! Your responses have been very helpful!

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#2196271 - 10/23/18 10:06 PM Re: Abundance of Caution Compliance Newbie
hmdagal Offline
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Keep in mind that if you're paying off an existing dwelling-secured loan to the same borrower (such as a previous SBA loan), your new loan will be reportable.

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