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#2153445 - 11/14/17 04:19 PM
Loan Purpose- Not Applicable.
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Member
Joined: Sep 2017
Posts: 58
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Good morning everyone,
I have a question regarding loan purpose.
It looks like a new loan purpose selection has been added as of 8/2017 (version 3.1 of filing instructions) The code is 5, which is "Not Applicable".
Looking over Paragraph 4 (a)(3), I do not see any commentary or guidance on how/when this code should be used. So I am wondering if we would use "NA" in the same manner as we do for certain, other data fields that require "NA" to be reported when the application is withdrawn by the application or closed for incompleteness. Would anyone happen to know? Are there specific guidelines as to when this code should be used?
Thank you!
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#2153460 - 11/14/17 04:43 PM
Re: Loan Purpose- Not Applicable.
Permissible Purpose
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10K Club
Joined: Nov 2002
Posts: 20,656
The Swamp
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Very good question. Bizarre!
Along those same lines, I'd like an example of a Business/Commercial purpose that falls into (2) Not primarily for a business or commercial purpose.
_________________________
My opinion only. Not legal advice. Say you'll haunt me - Stone Sour
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#2153465 - 11/14/17 05:06 PM
Re: Loan Purpose- Not Applicable.
Permissible Purpose
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Power Poster
Joined: Sep 2010
Posts: 2,662
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Joker, I thought code 2 in the Business/Commercial purpose field (#48) would be used for all consumer-purpose loans. Basically, if not subject to Reg Z, code 1. If subject to Reg Z, code 2.
Am I missing something?
_________________________
Adam Witmer, CRCM All statements are my opinion, not those of my employer, and should not be taken as legal advice. www.compliancecohort.com
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#2153475 - 11/14/17 05:31 PM
Re: Loan Purpose- Not Applicable.
Adam Witmer
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Member
Joined: Sep 2017
Posts: 58
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Thanks Adam. This is helpful info.
So if my institution never purchases covered loans, this code should never be used. Correct?
Thanks!
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#2153483 - 11/14/17 05:50 PM
Re: Loan Purpose- Not Applicable.
Adam Witmer
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10K Club
Joined: Nov 2002
Posts: 20,656
The Swamp
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Joker, I thought code 2 in the Business/Commercial purpose field (#48) would be used for all consumer-purpose loans. Basically, if not subject to Reg Z, code 1. If subject to Reg Z, code 2.
Am I missing something? Didn't even think about it in that context, Adam. That is the most likely explanation! !
_________________________
My opinion only. Not legal advice. Say you'll haunt me - Stone Sour
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#2153507 - 11/14/17 07:02 PM
Re: Loan Purpose- Not Applicable.
David Dickinson
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Member
Joined: Sep 2017
Posts: 58
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Thanks David! Great meeting you at the recent ABA Foundational Course BTW.
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#2237995 - 06/12/20 03:11 PM
Re: Loan Purpose- Not Applicable.
Permissible Purpose
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Diamond Poster
Joined: Oct 2015
Posts: 1,669
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What about for loans purchased after 1/1/2018? If nothing else is taking place, would you report the purpose as "Other," or do you report based on what it was when originated, i.e. get the info from the seller/existing documentation?
Last edited by Compliance NABW; 06/12/20 03:26 PM.
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#2238039 - 06/12/20 08:06 PM
Re: Loan Purpose- Not Applicable.
Permissible Purpose
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Member
Joined: Oct 2012
Posts: 92
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I would agree you're going to need to get the information from the seller/file documentation. As Adam stated, you can only use NA for loans you purchase that were made prior to January 1, 2018.
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#2238146 - 06/16/20 02:17 PM
Re: Loan Purpose- Not Applicable.
Diane Dean
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Diamond Poster
Joined: Oct 2015
Posts: 1,669
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Yeah, I wasn't calling for using "N/A," but thought that the Regulation could potentially be requiring this to be a form of an actual transaction where you would classify it an "Other" for Loan Purpose.
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