Hi all - I am having a difference of opinion with one of my loan officers. Here's the background.
A few years ago, a business was granted a LOC for the purpose of providing working capital for that business. The loan was secured by a 2nd mortgage on the business owners personal residence. Skip to a few months ago and the borrower applied for a 5 year loan to term out the line of credit. The new term loan was also to be secured by a second mortgage on the personal residence.
My feeling is that this is a reportable loan as we have a dwelling secured loan paying off and replacing a dwelling secured loan to the same borrower.
My loan officer is arguing that this is not reportable as the purpose of the term loan is to term out a LOC, which is an "Other" purpose, and therefore not HMDA reportable.
Expert guidance/opinions needed please.
Thank you,
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