We disclose the LE and report the transaction to HMDA as a Purchase. The Loan Amount would be higher than the Purchase Price. We haven't had any problems with the funds from borrower reflecting the correct amount on the LE.
Three things we encounter and have to watch for are:
Make sure LO is increasing the fees to accommodate the second property (Appraisal, Flood, Recording, etc). We have had to pay for a couple appraisals and flood certs because of LO errors.
Our LOS is set to figure the LTV based on the purchase price or appraised value, whichever it lower so we have to make sure we document that we used the Purchase Price/Lower on the Purchase + Appraisal on blanket property to calculate the true LTV. The underwriter can override the system calculation and update the LTV field accordingly.
HMDA fields may need manually adjusted to show the Property Value based on the underwriter calculation.
Last edited by jlroberts; 08/31/19 07:22 PM.