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#349100 - 04/20/05 03:49 PM HMDA Home Improvement
COMPLIcated Offline
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Joined: Mar 2003
Posts: 1,035
OK
If you have a loan that is for improvements to a rental property and it is secured by the primary residence, what information on the LAR relates to the house where improvements are made and what information relates to the collateral property?

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Lending Compliance
#349101 - 04/20/05 04:57 PM Re: HMDA Home Improvement
hmdagal Online
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hmdagal
Joined: Dec 2002
Posts: 3,824
For a home improvement loan, all information will relate to the property being improved.

For a home purchase or refinance, it will all relate to the collateral property.

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#349102 - 04/20/05 06:10 PM Re: HMDA Home Improvement
COMPLIcated Offline
Diamond Poster
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Posts: 1,035
OK
What would you put on the lien status then? You have a lien on the primary that is collateral but not on the house being improved...would you just put not secured by a lien?

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#349103 - 04/20/05 06:26 PM Re: HMDA Home Improvement
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,016
Bloomington, IN
You report your lien status for the dwelling securing the loan.

Page 17 of the GIR.

Lien Status. For every originated loan, report whether the loan is secured by a first or subordinate lien on a dwelling or is not secured by a dwelling.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#349104 - 05/23/05 04:35 PM Re: HMDA Home Improvement
Jan94 Offline
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Joined: Mar 2001
Posts: 828
USA
I have a similar situation, where the loan is home improvement but the collateral is a business property. It is a consumer loan and the improvement money is going toward the personal dwelling of the borrower but they did not want to take the personal residence as collateral. We were thinking that we would report it as 3 - not secured by a lien, but the GIR doesn't seem to address this scenario in either Appendix A or D. Confused....

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#349105 - 05/23/05 06:02 PM Re: HMDA Home Improvement
Anonymous
Unregistered

Quote:

I have a similar situation, where the loan is home improvement but the collateral is a business property.




You report the address of the property being improved and the lien status should be reflective of your collateral as Dan stated above. So, lien status would be 1 or 2, whichever is applicable to your "business property" taken as collateral.

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#349106 - 05/23/05 06:28 PM Re: HMDA Home Improvement
swiggles Offline
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swiggles
Joined: Aug 2001
Posts: 7,333
If this loan is not "classified" as a home improvement loan, it would not be reportable because it is not secured by a dwelling.
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The more you sweat in training, the less you bleed in battle.......

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#349107 - 05/23/05 07:11 PM Re: HMDA Home Improvement
Anonymous
Unregistered

I agree with swiggles. There are two things here:
1. Property is being improved = not secured by lien = not reportable
2. Property is secured by lien = business property = not reportable

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#349108 - 05/23/05 10:04 PM Re: HMDA Home Improvement
Anonymous
Unregistered

(ARose from above - forgot to login) The loan is classified as Home Improvement but the collateral is a commercial property (not a dwelling). Would we still report lien status when collateral is not a dwelling?

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#349109 - 05/23/05 10:09 PM Re: HMDA Home Improvement
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,016
Bloomington, IN
If you have classified the loan as home improvement then it is reportable. Your loan is not secured by a lien on a dwelling therefore you report 3.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#349110 - 05/23/05 10:21 PM Re: HMDA Home Improvement
Anonymous
Unregistered

Thank you, that's what I thought as well!

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