I have confused myself on this issue: if we are adding a new husband on a loan but keeping the original borrower, do we do HMDA on it? We already reported this home purchase and this loan number when the wife got the loan from us two years ago.
So you're not reunderwriting the loan or pulling a credit bureau on him, etc. Just recording the agreement he signs which amends the original mortgage she signed prior to their marriage. Got it.
IMO, not HMDA reportable. HMDA wants you to report on obligations that replace an existing one. You're not doing that.
We are now working with the same scenario at our bank. (adding the new spouse at renewal with a modification agreement) Does the new debtor need any RESPA disclosures? Just seems odd to have them jump into debt without any disclosures.