Just wanted to update. I had submitted the question to HMDA help just prior to posting the question here (I posted here because we all know how unhelpful HMDA help is). The following is what they sent me.
|
| To:
hmdahelp@frb.gov | Subject: Assumptions & HMDA
We have several loans which are currently in the names of husband and
wife (or 2 people). One of the current borrowers is going to assume
the
entire loan. There will be a new deed prepared with ownership being
transferred from the couple to the individual. Would this be HMDA
reportable as a purchase or refinance? Is it even reportable?
>>>
hmdahelp@frb.gov 5/10/2006 11:54:45 AM >>>
Did you already report these loans as home purchase loans? They would
qualify as a refinance only if they meet the HMDA reportable
definition: A
refinancing is (1) any dwelling-secured loan that (2) replaces and
satisfies (3) another dwelling-secured loan (4) to the same borrower.
2004
HMDA Guide, page 8.
http://www.ffiec.gov/hmda/guide.htm >---------------------------------------------------------------------------------------------------------------------- |
| To:
hmdahelp@frb.gov |
| Subject: Re: Assumptions & HMDA (D) |
I know the definition of a refinance. My question more relates to page
D-2 of the getting it right guide. It states that "An assumption occurs
when an institution enters into a written agreement accepting a new
borrower as the obligor on an existing obligation. An institution
reports as a home purchase loan an assumption in the amount of the
outstanding principal." Does changing the borrower from husband and
wife to husband only constitute a "new borrower?"
>>>
hmdahelp@frb.gov 5/10/2006 11:54:45 AM >>>
yes