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BankersOnline.com Forums Dodd-Frank Final Rules Discussions HMDA Overhaul 2018 Down Payment Second Mortgage
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#2260643 - 10/04/21 03:34 PM Down Payment Second Mortgage
RegComply Offline
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Joined: Jan 2012
Posts: 19
Southeast
We have some down payment second mortgage loans - the AUS in the file is for the first mortgage transaction and not the second would you report the AUS as not applicable or use the first mortgage AUS and its results for the HMDA LAR?

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#2260644 - 10/04/21 03:39 PM Re: Down Payment Second Mortgage RegComply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,358
Galveston, TX
What does the AUS have to do with the 2nd lien?
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#2260645 - 10/04/21 03:43 PM Re: Down Payment Second Mortgage RegComply
RegComply Offline
New Poster
Joined: Jan 2012
Posts: 19
Southeast
That is my argument - the second mortgage is only included in the AUS as a source for the down payment but the lender is including as if that AUS was used in "evaluating" the loan.

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#2260647 - 10/04/21 04:11 PM Re: Down Payment Second Mortgage RegComply
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,358
Galveston, TX
Then that is wrong.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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