After some clean-up here is the conversation.
FRB - response: Renewals are still not reportable for 2004 and forward.
Jesse - question: Thank you for your response to my question.
Will this statement regarding renewal of balloon loans still be true for reporting loans secured by a dwelling on the LAR in 2004 also?
Sincerely,
Jesse
FRB - response: Balloon loans are to only be reported once. Do not report the renewals of balloon loans.
Thank you for using HMDAHELP. Do you have the 2003 version of "The Guide to HMDA Reporting: Getting It Right!"? If not, go to
http://www.ffiec.gov/hmda/pdf/guide.pdf Jesse - question: To Whom It May Concern:
My questions are as follows:
Are we required to include renewals of balloon loans secured by dwellings as refinancings on the HMDA LAR?
1. Our loan agreements do not state that we "are unconditionally obligated to refinance the obligation, or you (we) are obligated to refinance the obligation subject to conditions within the borrower's control."
2. Our previous loan agreements state on the face of the new obligation that "This Note renews and does not satisfy or discharge a Note I executed to the Lender on _________________.
3. The software program that we currently use to draft our loan paperwork does not refer to previous notes. However, the statement in point number 2 could be inserted into our contracts if the bank should not be reporting renewals as refinancings on the HMDA LAR.
Should we include the statement quoted in point number 2 on our loan
documents?
If this statement is added are we still required to include the renewal on the HMDA LAR?
Sincerely,
Jesse