HMDA Reportable

Using a 2nd to pay off construction loans that were to build primary residence - term is 10 years. HMDA reportable?

Based on the information you provided - Yes.

I agree with Bonnie. You are converting a temporary "purchase money loan" into a permanent loan which is secured by a dwelling (the lien position plays no role in determining HMDA eligibility). The loan would be reported as a purchase.

Okay, it IS Friday, but why would you put a second in place? Won't you have LTV problems? I agree that it is reportable.......

Not necessarily. As an example we just converted a $540k constuction to perm. We put $300k in the secondary market (FHLMC) and put a 2nd on the home for $240k (total LTV 80%). Both loans are reported on our LAR as a purchase.

I would report this as a refi as it is refinacing (paying off a mortgage).

Look at page D-7 of the GIR.

5. Construction and permanent financing. A home-purchase loan includes both a combined construction/permanent loan AND the permanent financing that replaces a construction-only loan.

That was exactly the situation we had.