Skip to content
BOL Conferences
Thread Options
#2278434 - 12/03/22 02:41 AM HMDA Denial Reason - Collateral Questions
Help! Compliance Offline
100 Club
Joined: Oct 2012
Posts: 147
San Antonio, TX
HMDA Denial Reason - Code 4—Value or type of collateral not sufficient

Adequate value and condition of the dwelling collateral are an obvious fit.

Would these fall under the collateral denial reason (4), or would one report it under 9-Other?

1) Property Ownership issue with title
2) It was discovered that the 1st lien was an HE loan that needs to be paid off, and the applicant doesn't want to do so (Texas)
3) It was discovered that the property was a mobile/manufactured home, and one's bank does do loans for that collateral type
4) The title process discovered judgements on the subject property that the applicants cannot or will not remedy
5) Miscellaneous other issues related to the property discovered during the title process


Thanks for your help...
Last edited by Help! Compliance; 12/03/22 02:45 AM.
Return to Top
HMDA

   
HMDA Academy
#2278438 - 12/03/22 06:44 PM Re: HMDA Denial Reason - Collateral Questions Help! Compliance
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
None of those reasons to me seem to specifically relate to that HMDA Reason Code, but this is really a fact-based decision. Although I do not understand a couple of them. Like #2 - what sort of loan did they apply for? #5 is too much a catch all to opine on.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2278452 - 12/05/22 03:46 PM Re: HMDA Denial Reason - Collateral Questions rlcarey
Help! Compliance Offline
100 Club
Joined: Oct 2012
Posts: 147
San Antonio, TX
They applied for a HE loan, and it was discovered their 1st lien was already a HE loan, which means they are required to pay the 1st HE loan off...but they were unwilling and hoping to add the 2nd HE as a subordinate lien.

Return to Top
#2278480 - 12/05/22 11:55 PM Re: HMDA Denial Reason - Collateral Questions Help! Compliance
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
If the borrowers were applying for a second Home Equity Loan, then that is not even adverse action under Regulation B, since State law would prohibit such a transaction.

1002.2(c) Adverse action.

(2) The term does not include:

(iv) A refusal to extend credit because applicable law prohibits the creditor from extending the credit requested; or
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  SMQ, CRCM