more HMDA questions

Posted By: TammyatCFB

more HMDA questions - 02/09/11 08:11 PM

If you payoff a commercial revolving line of credit secured by several commercial properties and a 1-4 family residence and refinance to lower credit line amount would this be HMDA reportable?
Posted By: SMQ, CRCM

Re: more HMDA questions - 02/09/11 08:19 PM

Is the new loan a revolving LOC? Do you report your LOCs? If it is an LOC and your bank reports LOCs, then report as a refi.

If new loan is a closed end LOC, report as a refi.