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#2282931 - 03/31/23 07:11 PM HMDA exemption - temporary financing
ckme Offline
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ckme
Joined: Sep 2002
Posts: 255
Hello!
I have a question, what if we do a loan renewal on a matured consumer mortgage balloon note. In this case, we will payoff the existing loan and will have a new promissory note that is interest only for a year due to financial hardship. Our plan is to resume amortizing payments when it matures next year. Would this be exempt from HMDA as a temporary loan or reportable as a refinance?

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#2282936 - 03/31/23 07:44 PM Re: HMDA exemption - temporary financing ckme
raitchjay Offline
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Joined: Oct 2009
Posts: 9,105
OK
What you describe meets the HMDA definition of temporary financing--designed to be replaced by financing of a much longer term.
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#2282942 - 03/31/23 08:24 PM Re: HMDA exemption - temporary financing raitchjay
Melissa S Offline
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Melissa S
Joined: Jan 2015
Posts: 374
Maine
Raitchjay, does it make a difference in this situation if the new promissory note is designed to automatically convert to P&I payments at the end of the year of interest only? As opposed to this 2nd loan being interest only to be refinanced by a 3rd loan at P&I?
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#2282944 - 03/31/23 08:28 PM Re: HMDA exemption - temporary financing ckme
raitchjay Offline
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Joined: Oct 2009
Posts: 9,105
OK
Yes, Melissa, what you describe would not be temporary financing. Since the OP said they planned to resume amortizing payments "when it matures next year", their scenario would be temporary.
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