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#1641159 - 12/20/11 06:31 PM Filling out HMDA LAR
TammyatCFB Offline
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Joined: May 2010
Posts: 18
Loan is secured by a non o/o SFR to do improvements on primary residents. I report on the property being improved (primary residence)but I am not sure how to complete the rate spread, HOEPA status and lien status area's because the loan is secured by a non o/o SFR.

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#1641181 - 12/20/11 06:56 PM Re: Filling out HMDA LAR TammyatCFB
raitchjay Offline
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Joined: Oct 2009
Posts: 9,103
OK
If Reg. Z applies (and by the information you provide, it should in this scenario), you would need to report the numeric spread if over the threshold. HOEPA status should be reported as 2) Not a HOEPA loan. Do you have a first or subordinate lien on the NOO home? You should report the lien status of whatever home you are taking as collateral.
Last edited by raitchjay; 12/20/11 07:06 PM.
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