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#2255628 - 06/18/21 08:19 PM HMDA LAR Denial Reason non-homestead HE/HI TX?
Help! Compliance Offline
100 Club
Joined: Oct 2012
Posts: 147
San Antonio, TX
We have a HMDA reportable HE loan in TX that was denied due to the subject property not being the applicant's homestead. Would the denial reason be "4 - collateral" due to the type of collateral being a non-homestead1-4 family ("value or type of collateral"), or would this fall under the "9 - Other" category? Thanks!

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#2255629 - 06/18/21 08:32 PM Re: HMDA LAR Denial Reason non-homestead HE/HI TX? Help! Compliance
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
I don't think homestead versus non-homestead is a type of collateral. I would go with other.

I am also curious - you do not make any equity loans on non-homestead property? It is funny that you will not make a loan that has actual recourse against the borrowers, but will make loans that do not, from a credit risk standpoint
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#2255634 - 06/18/21 09:01 PM Re: HMDA LAR Denial Reason non-homestead HE/HI TX? rlcarey
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100 Club
Joined: Oct 2012
Posts: 147
San Antonio, TX
Cash-out Refi HE loans for investment property are done through our Mortgage Department. This was done through our Consumer Underwriting Department...so it would be considered policy/product specific. I appreciate your incite and help with this.
Last edited by pp1865; 06/18/21 09:02 PM.
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#2255635 - 06/18/21 09:03 PM Re: HMDA LAR Denial Reason non-homestead HE/HI TX? Help! Compliance
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,396
Galveston, TX
If it is all the same bank - you have a real problem with that statement. You cannot deny an applicant because they gave the application to the wrong department.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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