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#1730074 - 08/13/12 02:31 PM Refi or Purch
Learning Compliance position Offline
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Joined: Aug 2012
Posts: 19
I have a loan that a customer are refinancing their primary home to purchase another property (house/cabin etc). To my understanding, I know to use the address of the property being secured (their primary property) on the Lar, but do I code this as a purch or refi? and would it be owner or non owner occupied. I am getting mixed signals. Thank you.

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#1730093 - 08/13/12 02:57 PM Re: Refi or Purch Learning Compliance position
raitchjay Offline
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OK
Purchase trumps refi in the hierarchy of reporting, so it would be reported as a purchase. Owner occupancy is reported for the property that you are reporting property location for, which should be the property that you have as security. Since that's the primary residence of the borrowers, you should report it as owner-occupied.
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#1730099 - 08/13/12 03:07 PM Re: Refi or Purch Learning Compliance position
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
but do I code this as a purch or refi?

A little trick that has helped our loan officers.

Purpose Codes

1. Home Purchase
2. Home Improvement
3. Refinancing

To determine how to report the purpose of the loan look at all stated purposes of the loan request then report based on the numeric ranking of the loan purpose codes with 1 being the top ranked purpose.


would it be owner or non owner occupied. I am getting mixed signals.

Occupancy is based on whether the property being reported will be the property owner's primary dwelling.
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#1730105 - 08/13/12 03:14 PM Re: Refi or Purch Learning Compliance position
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What is messing with my head is the Purpose is for Home purose, but it's secured by another property.

I just dont know what to stick with. So on this loan. I know to code it as a purchase and use the correct address, but what is throwing me is now you say to code it as owner occupied. The item they are purchasing would be non owner occupied. so DO I just now go off of what property is being secured? and also use that for lien status?

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#1730110 - 08/13/12 03:20 PM Re: Refi or Purch Learning Compliance position
Skittles Online
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TN
Yes - you use the property as collateral when determing the codes.
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#1730114 - 08/13/12 03:21 PM Re: Refi or Purch Learning Compliance position
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 47,533
Bloomington, IN
A home purchase is any dwelling secured loan for the purpose of purchasing a dwelling.

No where in the definition does it refer to the dwelling securing the loan has to be the dwelling being purchased. The same holds true for a refinancing.

For property location:

Home Purchases & Refinancings - if the property securing the loan is not the property being purchased or refinanced then you report the property securing the loan.

Home Improvements - you report the property being improved.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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