We do biweekly loans here at my FI. For HMDA, should I report the term rounded up? Or actual term? For example 13 years, 5 months, I would report 161 months.
#2163085 - 02/05/1802:32 PMRe: Biweekly loan term Tracey, CRCM
Adam Witmer
Power Poster
Joined: Sep 2010
Posts: 2,658
Comment 2 to 1003.4(a)(25) states the following:
2. Non-monthly repayment periods. If a covered loan or application includes a schedule with repayment periods measured in a unit of time other than months, the financial institution should report the covered loan or application term using an equivalent number of whole months without regard for any remainder.
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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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