I have a loan where we are doing a refinance of the original Note for the purpose of funds for their business. This loan was done here as a "Business Loan" for a family resturant. The collateral is the resturant AND their primary residence.

So based on the fact that we are satisfying and replacing the original Note that had the primary residence along with their business on it as well, I would say this is HMDA applicable?? Is there anything else I'm missing that would deem it otherwise?

Thanks!

You're not missing anything. It meets the definition of a refinancing under HMDA.

Remember if you are a CRA reporting bank that the loan would be reported as a small business loan since it is secured by residential RE.

Thanks guys! I am extremely grateful for this website! Ever since we had such a massive layoff and too few for too much, it is hard to do such extensive research on every single thing any more. I'm sure many on here can totally relate!

This website has helped me confirm many things b/c of so many smart people as well as research and put my hands on many regs extremely fast and I am so thankful!

Thanks again!
KT

KCGeoQueen are you talking about it not being reported as HMDA? I agree with Dan on this one. It would be reported on the HMDA LAR.

I think KC meant that if you tracked SB CRA loans secured by Resi RE for consideration, you would include it with those loans but yes it is a HMDA reportable loan.

I think KC means to show it as loan type 3, "other small business loans / lines of credit" that are not reported but may be tracked by a bank.

Thanks everybody, actually I left a "not" out and should have said it is NOT reported as a small business loan. However, as my great buddies have said (covering my 6) if you do use type 3 loans in your exam process, it would go there.

Is it 5pm yet???

It's Ok, KC...You were just having a Rizzo moment!!

Well thank you Riz, it is an honor to be in your class.