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#2247135 - 01/04/21 08:49 PM LOC - Working Capital
Melissa S Offline
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Melissa S
Joined: Jan 2015
Posts: 374
Maine
I have a commercial borrower who requested a LOC to provide working capital needs for a business. The line is collateralized by the business assets (no real estate) of the business borrower, but also with an abundance of caution mortgage on a personal residence.

I understand that the abundance of caution does not negate the necessity of reporting, depending on the loan. Where this is for business working capital, not a home purchase line, a refi, or for home improvements, I am assuming this is not reportable as commercial loans do not report "other"?

Thank you.
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HMDA

   
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#2247142 - 01/04/21 09:11 PM Re: LOC - Working Capital Melissa S
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,357
Galveston, TX
Same answer as the other thread going on right now - not reportable.
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#2247143 - 01/04/21 09:12 PM Re: LOC - Working Capital Melissa S
Melissa S Offline
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Melissa S
Joined: Jan 2015
Posts: 374
Maine
Sorry RL - i missed the other thread, or I would not have posted.
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#2247160 - 01/05/21 12:36 PM Re: LOC - Working Capital Melissa S
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,658
For reference in case anyone else reads this looking for the same answer, a loan secured by personal residence is subject to HMDA, regardless if the mortgage was taken out of an abundance of caution. In other words, there are no exceptions for taking collateral as an abundance of caution. That said, this loan is not reportable as "other" purpose, business-purpose loans are not reportable. If the loan had a purpose of a purchase, refinance, or home improvement, it would have been reportable.
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#2247162 - 01/05/21 01:46 PM Re: LOC - Working Capital Melissa S
Melissa S Offline
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Melissa S
Joined: Jan 2015
Posts: 374
Maine
Thank you, Adam
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