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#2242655 - 09/17/20 09:35 PM HMDA Application
HMDA is my life Offline
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Joined: Oct 2015
Posts: 55

This is the situation...We have a borrower that wants to purchase his dad's house, which he lives in. Our LO says he had a prequal on 2-14 and said he recived the application 3-13. When questioned about it he said he did not have an "address" and therefore did not have an app for HMDA or TRID. When asked what of the 6 pieces of info he did not have, he says he did not have an address. I say he had a loan location (app for HMDA) and needed to send out disclosures (TRID). What constitutes a property address for HMDA. I know that if there is a manufactured home in play and don't have any land to put it on it is a dwelling and therefore HMDA reportable. Can anybody weigh in on this?

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#2242694 - 09/18/20 02:41 PM Re: HMDA Application HMDA is my life
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
If he already lives in the house that he wants to purchase, how does the loan officer not have an address? If the applicant didn't provide it, I can buy that, but it seems unlikely.
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#2242751 - 09/18/20 08:12 PM Re: HMDA Application HMDA is my life
Andy_Z Offline
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I would want some information corroborating that I told my own dad I'd buy his home, but I didn't know the address. The reason I might get snarky on this is because it seems the lender is gaming the system - "No, don't tell me the address yet, I don't need that now" which could be viewed by some as purposely turning a blind eye to avoid making consumer disclosures. The next step is the lender saying, "tell me this signature loan is business related and I can make it today, otherwise come back in a few days for a consumer loan."

The address is commonly accepted to be the street address, not a lot and block description.
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#2242755 - 09/18/20 08:21 PM Re: HMDA Application HMDA is my life
Skittles Offline
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Joined: Sep 2002
Posts: 13,965
TN
Did they pull a credit report? If so, they probably had the street address.
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