Land Loan Paid off with New Dwelling

Posted By: Compliance Newbie

Land Loan Paid off with New Dwelling - 12/10/18 03:19 PM

Customer has a land secured loan with another bank with a balance of $9,300. The customer built a dwelling (appraised value $111,000) this year on this land with their own money. We are now taking this home as collateral on a loan (65% LTV) and paying off this land loan with this other bank. Would this new loan now be HMDA reportable? Refinance? or Purchase?
Posted By: RR Joker

Re: Land Loan Paid off with New Dwelling - 12/10/18 07:08 PM

I would say yes as the original land loan became secured by a dwelling by the fact it now exists and is not readily movable/chattel-type property.
Posted By: raitchjay

Re: Land Loan Paid off with New Dwelling - 12/10/18 07:16 PM

I agree, and i'd call it a refinance (as opposed to a home equity loan).
Posted By: Adam Witmer

Re: Land Loan Paid off with New Dwelling - 12/10/18 09:02 PM

FWIW, I also agree and would call it a refinance.