Thread Starter: KerryG
Title: Re: 2 HMDA Questions
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1) Acreage only pertains to Reg Z & RESPA; it has no bearing on HMDA.
2) If the new lien is "new money" and not existing debt secured by a dwelling (not necessarily the same dwelling), it is not HMDA reportable. To illustrate, Mr. Customer has a first lien on his home for $100,000. He just obtained a second lien on the home for $15,000. The second lien would not be reportable (because no dwelling secured debt was refinanced, the $15,000 is new debt). However the $15,000 second lien would be HMDA reportable if the funds are being used for home improvements to be made.
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