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#980916 - 06/24/08 03:46 PM purchase dealer financing - HMDA?
sooner or later Offline
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Joined: Oct 2006
Posts: 57
We are doing some loans where the Bank is purchasing the dealer contracts for purchase of mobile homes. The loans are secured by the mobile home and the real estate (real estate is already owned by the borrower). In some cases there is an existing home on the property and a portion of the loan proceeds pays off the previous lender as well as purchase of the new mobile home. These loans are 9 month loans that will be paid off by a mortgage company.

My question is, since the loan proceeds for these refinance loans are also used to purchase a home, are the loans HMDA reportable?
Note: we do not report "temporary" purchase loans but we do report loans that are for home improvement or refinance even if our subject loan will be paid off by long term financing.

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#980960 - 06/24/08 04:11 PM Re: purchase dealer financing - HMDA? sooner or later
Dan Persfull Online
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Dan Persfull
Joined: Aug 2002
Posts: 47,532
Bloomington, IN
If any portion of the loan proceeds is for the purpose of a purchasing a dwelling then the transaction is a home purchase loan under the HMDA definitions. Sounds like these are temporary loans and would not be reportable.
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The opinions expressed are mine and they are not to be taken as legal advice.

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