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#335476 - 03/18/05 05:07 PM HMDA Refi HI loan question
Anonymous
Unregistered

We are refinancing a loan that was used for HI by the borrower. Is this loan HMDA reportable?

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Lending Compliance
#335477 - 03/18/05 05:13 PM Re: HMDA Refi HI loan question
someone else Offline
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someone else
Joined: Aug 2004
Posts: 3,300
back to my roots
If you are satisfying and replacing a lien with another dwelling-secured lien for the same borrower, then yes, it is HMDA reportable. It does not really matter what the purpose of the previous loan was. It only matters what the purpose of proceeds of the current loan is. Are any of the proceeds going to Home Improvement again? If so, this would not be classified as a refinance, rather it would be a HI loan.
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#335478 - 03/18/05 05:18 PM Re: HMDA Refi HI loan question
Anonymous
Unregistered

I should clarify the above post. The loan we refinanced is unsecured. There were no new money advanced, so I'm leaning to the "not reportable" side of the argument.

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#335479 - 03/18/05 05:21 PM Re: HMDA Refi HI loan question
Dan Persfull Offline
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Dan Persfull
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Posts: 47,030
Bloomington, IN
You are leaning in the right direction.
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#335480 - 03/18/05 06:20 PM Re: HMDA Refi HI loan question
someone else Offline
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someone else
Joined: Aug 2004
Posts: 3,300
back to my roots
Now that I know the details, I am leaning that way too...

leaning way to the right in my chair...falling over...can't get up...
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Somewhere, something incredible is waiting to be known. - Carl Sagan

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#335481 - 03/28/05 08:08 PM Re: HMDA Refi HI loan question
Jan94 Offline
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Joined: Mar 2001
Posts: 828
USA
If there was "new money" advanced to this HI unsecured refinance, and the new money was used for something other than HI, would this be reportable as a refinance? Both the original and refinanced loan are still unsecured. If the new money was used for HI and the 2 loans are still unsecured, would it be reported as a HI loan or not reported at all?

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#335482 - 03/28/05 08:14 PM Re: HMDA Refi HI loan question
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,030
Bloomington, IN
An unsecured refinancing of an unsecured HI loan is not reportable unless a portion of any new money will be used for HI purposes and the new loan is classified as a HI loan. It would then be reported as a HI loan.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#335483 - 03/28/05 08:18 PM Re: HMDA Refi HI loan question
hmdagal Offline
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hmdagal
Joined: Dec 2002
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If there was "new money" advanced to this HI unsecured refinance, and the new money was used for something other than HI, would this be reportable as a refinance?

No. Both loans have to be secured by a lien on a dwelling to be reportable as a refinance.

If the new money was used for HI and the 2 loans are still unsecured, would it be reported as a HI loan or not reported at all?

If the new loan is classified as a home improvement loan, it would be reportable as HI. If you do not classify your HI loans, then it would not be reportable at all.

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