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#2212201 - 04/26/19 01:04 PM 2 reportable transactions or just 1?
LoveHMDA Offline
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I have an application from an entity to purchase a SFR investment property. We approved the loan request, but did not approve the entity, so the customer used another entity to do the loan. Do I need to treat this transaction as a counteroffer (we will approve your loan if you do it under this entity) or do I need to report the first application as a denial or approved not accepted?

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#2212202 - 04/26/19 01:10 PM Re: 2 reportable transactions or just 1? LoveHMDA
RR Joker Offline
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I would have done a denial with a C/O and reported all as one.
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#2212244 - 04/26/19 06:47 PM Re: 2 reportable transactions or just 1? LoveHMDA
Mountaineers_Fan Offline
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I may be missing something but to me it sounds like you have 2 transactions to report. Loan Request 1: Denial since you said you did not approve the entity (I'm assuming you're talking about a business entity). Loan Request 2: Origination

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#2212272 - 04/27/19 03:32 PM Re: 2 reportable transactions or just 1? LoveHMDA
Andy_Z Offline
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There are many things that can can be countered, but a change in borrowing entity isn't one of them as I would see it. I understand there mat be a number of entities that revolve around say one key entity, Jane owns three other companies and Company A wasn't approved but you knew Company B would be, but it is so much cleaner to to handle it as 2. I don't know your particulars and could see a defense in the situation I mentioned, but it would not be my preferred process. I have seen Dick apply for a loan but instead the loan was made to Jane who had better credit and qualified, but that would be two separate requests IMHO even if they were married and the funds were going to a joint account. Telling Dick he isn't qualified but the loan can go to Jane is more denial than counteroffer.
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#2212281 - 04/29/19 01:23 PM Re: 2 reportable transactions or just 1? LoveHMDA
RR Joker Offline
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Makes sense to me. I think I got lost in the customer being one and the same.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

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