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BankersOnline.com Forums Dodd-Frank Final Rules Discussions HMDA Overhaul 2018 Land Loan Paid off with New Dwelling
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#2200211 - 12/10/18 03:19 PM Land Loan Paid off with New Dwelling
Compliance Newbie Offline
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Joined: Jan 2015
Posts: 79
Customer has a land secured loan with another bank with a balance of $9,300. The customer built a dwelling (appraised value $111,000) this year on this land with their own money. We are now taking this home as collateral on a loan (65% LTV) and paying off this land loan with this other bank. Would this new loan now be HMDA reportable? Refinance? or Purchase?

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#2200242 - 12/10/18 07:08 PM Re: Land Loan Paid off with New Dwelling Compliance Newbie
RR Joker Offline
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Joined: Nov 2002
Posts: 20,656
The Swamp
I would say yes as the original land loan became secured by a dwelling by the fact it now exists and is not readily movable/chattel-type property.
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#2200250 - 12/10/18 07:16 PM Re: Land Loan Paid off with New Dwelling Compliance Newbie
raitchjay Online
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Joined: Oct 2009
Posts: 9,105
OK
I agree, and i'd call it a refinance (as opposed to a home equity loan).
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#2200267 - 12/10/18 09:02 PM Re: Land Loan Paid off with New Dwelling Compliance Newbie
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,658
FWIW, I also agree and would call it a refinance.
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All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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