Skip to content
GeoDataVision
Thread Options
#2263608 - 12/14/21 03:51 PM Withdrawn or Not HMDA Reportable
JoAnne S Offline
New Poster
Joined: Aug 2020
Posts: 8
I have 2 applications for a refinance- one for a 1st lien and one for a 2nd lien on same property. During the application process, the 2nd lien was removed and "unlinked" and the amount was added to the first. The 2nd lien refi was NOT expressly withdrawn by the applicant, this was all done internally. Is the 2nd lien loan reportable for HMDA or is this just a dead file?

Return to Top
HMDA

   
HMDA Academy
#2263612 - 12/14/21 04:55 PM Re: Withdrawn or Not HMDA Reportable JoAnne S
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,798
Cape Cod
Welcome to BankersOnline's Discussion Forums, and congratulations on your first of what we hope are many posts!

How is it that the bank departed from what the customer requested and combined the two requests into one? Did the customer agree to that change (applicants sometimes ask for a separate second-lien loan they can pay down and out sooner than the first-lien loan)?

Did the bank tell the applicant it would be able to make the first-lien loan for the combined amount, and the applicant agreed?
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top