Posted By: Princess of Power
To File or Not to File ??? - 02/06/15 08:44 PM
I am getting push back and need your opinions as to whether we need to file HMDA for CY 2014. I do not believe we need to file based on the definition of "Who Must Report" in the Guide to HMDA Reporting.
My review of potential HMDA loans in 2013 reveals that we originated 4 loans where the borrower owned the property (multi-family)free & clear. The purposes were varied, but NO proceeds were used to purchase any other R/E, but rather to reimburse themselves for improvements or other investment purposes.
I say we do not have to report for 2014 (but will in 2015 as we did originate in 2014 - 2 purchase $ loans 1-4, 1 purchase $ loan multi family and 1 refi of a purchase $ loan 1-4).
And the collective folks at BOL say?
Thanks
My review of potential HMDA loans in 2013 reveals that we originated 4 loans where the borrower owned the property (multi-family)free & clear. The purposes were varied, but NO proceeds were used to purchase any other R/E, but rather to reimburse themselves for improvements or other investment purposes.
I say we do not have to report for 2014 (but will in 2015 as we did originate in 2014 - 2 purchase $ loans 1-4, 1 purchase $ loan multi family and 1 refi of a purchase $ loan 1-4).
And the collective folks at BOL say?
Thanks