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#2259636 - 09/13/21 06:39 PM HMDA Reportable?
jel99 Offline
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Joined: Sep 2021
Posts: 3
The loan is for a down payment on a property in South America. It is on permanent financing and secured by two rental dwellings in the U.S.. Would this be HMDA reportable?

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#2259638 - 09/13/21 06:51 PM Re: HMDA Reportable? jel99
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,370
Bloomington, IN
Since the loan will be secured by dwellings located in the U. S. it would be reportable. However since the property being purchased does not qualify as a dwelling the loan would not be a purchase.

(c) Scope. This part applies to financial institutions as defined in §1003.2(g). This part requires
a financial institution to submit data to the appropriate Federal agency for the financial institution
as defined in §1003.5(a)(4), and to disclose certain data to the public, about covered loans for
which the financial institution receives applications, or that it originates or purchases, and that
are secured by a dwelling located in a State of the United States of America, the District of
Columbia, or the Commonwealth of Puerto Rico.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#2259639 - 09/13/21 06:52 PM Re: HMDA Reportable? jel99
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,564
Since the collateral is two rental dwellings in the US, yes this is HMDA reportable (unless another exemption applies).

(c) Scope. This part applies to financial institutions as defined in § 1003.2(g). This part requires a financial institution to submit data to the appropriate Federal agency for the financial institution as defined in § 1003.5(a)(4), and to disclose certain data to the public, about covered loans for which the financial institution receives applications, or that it originates or purchases, and that are secured by a dwelling located in a State of the United States of America, the District of Columbia, or the Commonwealth of Puerto Rico.
_________________________
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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