The underwriting for the loan being reported, however, does not rely on, nor include, any information on possible other collateral through cross-collateralization.....All decisions on the loan being reported are based on the direct property collateral to that loan alone.
Unless you can show something within the regulation, commentary, FIG or GIR that exempts dwelling units securing the loan by a cross-collateralization clause what is your regulatory basis for excluding them?
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The opinions expressed are mine and they are not to be taken as legal advice.