Thread Options
|
#2156783 - 12/11/17 05:27 PM
HMDA Scenario Check
|
Platinum Poster
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?
|
Return to Top
|
|
|
|
#2157162 - 12/13/17 07:47 PM
Re: HMDA Scenario Check
Carolina Blue
|
Power Poster
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
|
Return to Top
|
|
|
|
#2157168 - 12/13/17 08:10 PM
Re: HMDA Scenario Check
Carolina Blue
|
Power Poster
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)
_________________________
Jim Bedsole, CRCM, CBA, CFSA, CAFP My posts - my opinions
|
Return to Top
|
|
|
|
#2157173 - 12/13/17 08:42 PM
Re: HMDA Scenario Check
Carolina Blue
|
Platinum Poster
Joined: Jun 2014
Posts: 568
Petersburg, VA
|
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?
|
Return to Top
|
|
|
|
#2157175 - 12/13/17 08:51 PM
Re: HMDA Scenario Check
RVFlyboy
|
Power Poster
Joined: Sep 2010
Posts: 2,661
|
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
|
Return to Top
|
|
|
|
#2157176 - 12/13/17 08:52 PM
Re: HMDA Scenario Check
burke116
|
Power Poster
Joined: Sep 2010
Posts: 2,661
|
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
|
Return to Top
|
|
|
|
|
|