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#350442 - 04/22/05 05:43 PM Is this HMDA?

Deal is a refinance, collateral is 30 acres (non-farming acerage). Borrower resides in an older mobile home on the land securing our loan.

The loan that we are retiring did not include the mobile home, secured by the 30 acres only. New loan, 30 acres not the mobile home.

Because we did not and do not have an interest in the dwelling I'm thinking this is not HMDA but I'm not very sure of myself. Any other thoughts on this??

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Lending Compliance
#350443 - 04/22/05 05:57 PM Re: Is this HMDA?
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To be a refi under HMDA, both the old and the new loan would have to be secured by a dwelling. Since the old loan did not include the dwelling, no HMDA.

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