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#2218682 - 07/29/19 08:37 PM What is the HMDA Purpose?
Brooke H Offline
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Joined: Mar 2015
Posts: 44
We have a loan where the borrower inherited a home. The home had a lien on it and the borrower got the loan to pay off the lien. The lien was not in the borrower's name (it was in the name of the deceased), so I am questioning if this would be a refinance for HMDA?

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#2218685 - 07/29/19 08:56 PM Re: What is the HMDA Purpose? Brooke H
raitchjay Offline
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Not a HMDA refinance (at least one of the borrowers must be the same on the new loan and the loan being extinguished). (I'm not sure by your reference to a lien if a loan is being paid off or some other type of lien....a tax lien for example....but regardless, it isn't a refinance.) Sounds like a home equity loan for HMDA, unless there's missing information about a home purchase or home improvement that is going on.
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#2218689 - 07/29/19 09:10 PM Re: What is the HMDA Purpose? Brooke H
raitchjay Offline
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Actually...i was mixing TRID and HMDA terms....there is no choice for "home equity" for HMDA...it would be an "Other".
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#2218692 - 07/29/19 09:40 PM Re: What is the HMDA Purpose? Brooke H
Truffle Royale Offline

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kinda on the fence here. When the borrower inherited the home, did they agree to take on the debt too? Or is the estate paying it off? If it's the first, I might stretch that it's a refi. No, it's not the same named borrower but the debt was assumed by the borrower so, imho, they're technically the same borrower. I'm open to being dissuaded from this line of thought tho.

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#2218695 - 07/29/19 09:58 PM Re: What is the HMDA Purpose? Brooke H
raitchjay Offline
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I don't think they're the same borrower regardless. If the first loan was in the name of John Doe and now Marvin Public has inherited the home, the fact that the debt may now be in his name doesn't make it a HMDA refinance....it wasn't in his name when the original loan got made and Reg. C says that matters...IMHO.
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#2218700 - 07/29/19 11:35 PM Re: What is the HMDA Purpose? Brooke H
Brooke H Offline
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Joined: Mar 2015
Posts: 44
Thank you. Yes, it is a loan that is being paid off. I was leaning toward "Other" as the HMDA purpose.

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