An unsecured home improvement loan (one month term) to be paid off with the real estate loan is considered a bridge loan and not HMDA reportable, correct?

But will we be able to report the real estate loan as a home improvement loan when the funds were already disbursed on the consumer non-real estate loan? It will not be HMDA as a refinance (payoff unsecured HI loan) because the loan that will be paid-off is unsecured.

Thanks,

First, do you choose to report unsecured HI loans? If yes, why? Sorry, snarky response... :-) I've been too confused by temp financing today, so I'll let someone else chime in who reports unsecured HI loans on the temp financing exemption question.

But regarding the second loan, it does not sound reportable - doesn't sound like any funds going to a purchase, and not a refi if not paying off another dwelling secured loan, and it's not HI if the funds aren't going to fund future improvements. My understanding is it is not a HI loan if the funds are going to "reimburse the borrower" for improvements already made.

IMO, the first loan is not a bridge loan, but does qualify for the temporary financing exemption. I would argue that the real estate loan also isn't reportable as the funds weren't used for home improvement and it doesn't pay off a dwelling secured loan.

I agree with CRL & TMatt. Neither loan will be reportable based on the information provided.

We report and code unsecured HI loans. So the first loan is not reported because it's a temporary financing that is going to be replaced by a permanent longer term financing. The real estate is not reported because it does not fit the definition of a purchase, refinance or home improvement.

Thank You.

Okay. Thank you all.