HMDA Question

Posted By: Skittles

HMDA Question - 11/04/21 03:10 PM

Good morning,

Situation: For portfolio mortgage loans the decision was made that if the loan had been completely underwritten and approved - then the customer requests additional funds the process had to be started again. The thought process was since the request would require another review by underwriting this would be a new request. I know TRID allows a change in loan amount - and our secondary investors allow this. We originate a good number of portfolio mortgage loans.

I would love anyone's thoughts. My time here is winding down and I'm trying to do everything I can before I retire.
Posted By: Dan Persfull

Re: HMDA Question - 11/04/21 06:55 PM

I'm not quite sure what you are looking for but in this case we would treat it as one loan request for HMDA purposes.

3. Application date—reinstated application. If, within the same calendar year, an applicant asks
a financial institution to reinstate a counteroffer that the applicant previously did not accept (or
asks the institution to reconsider an application that was denied, withdrawn, or closed for
incompleteness), the institution may treat that request as the continuation of the earlier
transaction using the same ULI or NULI or as a new transaction with a new ULI or NULI. If the
institution treats the request for reinstatement or reconsideration as a new transaction, it reports
the date of the request as the application date. If the institution does not treat the request for
reinstatement or reconsideration as a new transaction, it reports the original application date.
Posted By: Skittles

Re: HMDA Question - 11/04/21 07:00 PM

Thanks Dan - that is helpful - as always!