If we make a HMDA reportable loan and within the first month that loan is refinanced because the borrower wanted to remove his wife's name from the loan, do we have two HMDA reportable loans? The first loan was not intended to be temporary when it was made - it was paid off and a new note written. On the other hand, it seems like reporting both loans is giving inaccurate data.

In reply to:

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On the other hand, it seems like reporting both loans is giving inaccurate data.

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You hit the nail on the head! This is my biggest complaint with HMDA. It's just so...GIGO! (Garbage In, Garbage Out.)

Quite frankly, I don't see any way out of NOT reporting BOTH loans. The first loan was entered into with all the intention of being a regular loan. The fact that it paid off early does not make it "temporary." Temporary financing is entered into with the full intent of being "temporary" - i.e. repayment is EXPECTED to be from a more permanent source rather than regular income.

But - that is what makes HMDA so fun, and so unreliable. It will be an anomoly in any analysis you might do, but that's life.

HMDA - the Reg that makes you go "Hmmmmmm....." (duh!)

I agree with Bonnie. If you make a new loan, you have a new HMDA entry.

Ditto.....Bonnie M

In Texas, due to some title insurance rules, many times we refinance a loan by filing an extension or modification of note and lien (one document to be filed in the real estate records at the courthouse). There is no new promissory note. For that reason, we cannot report some refi's.....that would otherwise be reported if a new note had been executed.

GIGO, to be exact!!