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#2218953 - 08/01/19 07:38 PM Seoond (Vacation) Homes / Rate Spread
LoveHMDA Offline
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Joined: Nov 2005
Posts: 283
Are second (vacation) homes subject to Rate Spread reporting?

I've been told yes that it is required to be reported, but I found in 1026.35(a)(1), that Section 35, high-priced mortgage loans, means a closed-end consumer credit transaction secured by the consumer's principal dwelling. Since the second home is not the consumers principal dwelling, would that eliminate the rate spread from being reported?

The kicker is, Reg C states that you report loans that originate or have been approved and not accepted that are subject to Reg Z, other than assumptions, purchased covered loans, and reverse mortgages. I don't see an exemption for second homes.

Any help that can be given will be greatly appreciated.

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#2218955 - 08/01/19 07:54 PM Re: Seoond (Vacation) Homes / Rate Spread LoveHMDA
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
There is no correlation between reporting rate spreads for HMDA and the coverage of Section 35.
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#2218957 - 08/01/19 08:06 PM Re: Seoond (Vacation) Homes / Rate Spread LoveHMDA
Mountaineers_Fan Offline
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Joined: Jun 2018
Posts: 100
Yes, second homes are subject to rate spread reporting.

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#2218995 - 08/02/19 01:43 PM Re: Seoond (Vacation) Homes / Rate Spread LoveHMDA
LoveHMDA Offline
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Joined: Nov 2005
Posts: 283
Thank you rlcarey and Mountaineers_Fan, I appreciate y'alls help!

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