Here is the scenario, please let me know if you agree or disagree...

We are going to be doing a first mortgage on a home that is for the purpose of purchasing a house. We are also going to do a second on the customers current home while it is on the market to sell. The second on the current home is to shore up the difference in equity (basically get us to 80% LTV on the new first). For the 1st we are going to do interest only for a year to give the borrower some time to sell their existing home, then we will modify into principal and interest.

So my thoughts are that the first mortgage to purchase the home is NOT temporary financing because the intent is that this will be the perm financing, it will just get modificed. Therefore, we should disclose as a regular purchase money and report as HMDA.

I also think we should report the second mortgage as HMDA reportable because the purpose of the funds is to purchace the property property. Similar to a purchase money second, its just the mortgaged property is different than the first.

Agree or Disagree with my assessment?????

I agree on the 1st. If it is the permanent financing and from the form of repayment it appears to be.

The second mtg. loan as described is a bridge loan. Bridge loans are exempt.

Thanks!