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#2156783 - 12/11/17 05:27 PM HMDA Scenario Check
Carolina Blue Offline
Platinum Poster
Carolina Blue
Joined: Jul 2005
Posts: 961
Lost in a regulatory fog
I'd appreciate anyone's input for the following situation to see if I'm on the right track.

John Doe applies to refinance three duplexes (121, 123, 125 Maple St.) and a manufactured home (127 Maple St) to get cash out to make improvements to the dwellings. He tells us his income is $100,000 and the value of the four dwellings is $300,000. He wants to borrow $150,000 ($75,000 to payoff current loan and &75,000 for improvements). So with that background, we would report the following:
loan is a refinance (we don't price differently for cash out),
we pick which dwelling address to report (assuming improvements are made at each dwelling).
we report the construction method, occupancy type and geocode for the property we chose,
we report the income and DTI since no single dwelling is multi-family, but if we only relied on the debt service coverage for the properties then we report income and DTI as NA.
we report the combined LTV of all properties- so 50%
we report the property value of all collateral- so $300,000
Number of units will be 7.
we do not report affordable housing units since no single dwelling is multi-family.

Correct?

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#2157162 - 12/13/17 07:47 PM Re: HMDA Scenario Check Carolina Blue
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,661
loan is a refinance agree
we pick which dwelling address to report -agree
we report the construction method, occupancy type and geocode for the property we chose -agree
we report the income and DTI since no single dwelling is multi-family -agree
but if we only relied on the debt service coverage for the properties then we report income and DTI as NA. -disagree as I don't know how you can calculate a DSC ratio without considering income
we report the combined LTV of all properties- so 50% -agree, assuming this is what you relied on
we report the property value of all collateral- so $300,000 -agree, assuming this is the amount you relied on
Number of units will be 7. -disagree - you report the number of units in the property you choose to report [see comment 4(a)(9)-2]
we do not report affordable housing units since no single dwelling is multi-family. -agree
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2157168 - 12/13/17 08:10 PM Re: HMDA Scenario Check Carolina Blue
RVFlyboy Offline
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RVFlyboy
Joined: Oct 2000
Posts: 5,991
Soaring over Georgia
Number of units will be 7. -disagree - you report the number of units in the property you choose to report [see comment 4(a)(9)-2] I disagree with your disagreement. Read all of comment 4(a)(9)-2, especially the last sentence of that comment, keeping in mind that number of units is 1003.4(a)(31)
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Jim Bedsole, CRCM, CBA, CFSA, CAFP
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#2157173 - 12/13/17 08:42 PM Re: HMDA Scenario Check Carolina Blue
burke116 Offline
Platinum Poster
Joined: Jun 2014
Posts: 568
Petersburg, VA
Quote:
we pick which dwelling address to report (assuming improvements are made at each dwelling).

Just wondering, if this would be reported as a refi (which I agree that it will be in 2018), what's the point in distinguishing whether or not improvements are made at each dwelling?

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#2157175 - 12/13/17 08:51 PM Re: HMDA Scenario Check RVFlyboy
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,661
Originally Posted By BeechFlyboy
Number of units will be 7. -disagree - you report the number of units in the property you choose to report [see comment 4(a)(9)-2] I disagree with your disagreement. Read all of comment 4(a)(9)-2, especially the last sentence of that comment, keeping in mind that number of units is 1003.4(a)(31)


I love the disagreement of the disagreement, Jim.

Ah, yes. Moving a bit too fast today and you are correct in the reference to the last sentence:

For aspects of the entries that do not refer to the property identified in § 1003.4(a)(9) (i.e., § 1003.4(a)(1) through (4), (7), (8), (10) through (13), (15) through (28), (31) through (38)), Financial Institution A reports the information applicable to the covered loan or application and not information that relates only to the property identified in § 1003.4(a)(9).
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2157176 - 12/13/17 08:52 PM Re: HMDA Scenario Check burke116
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,661
Originally Posted By burke116
Quote:
we pick which dwelling address to report (assuming improvements are made at each dwelling).

Just wondering, if this would be reported as a refi (which I agree that it will be in 2018), what's the point in distinguishing whether or not improvements are made at each dwelling?


I have no idea.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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