To File or Not to File ???

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
Posted By: Princess of Power

Re: To File or Not to File ??? - 02/07/15 12:30 AM

No opinions?
Posted By: Rocky P

Re: To File or Not to File ??? - 02/08/15 08:56 PM

2013 scenario = cash out refi - No HMDA

2014 scenario, do not understand. PoP, can you please write it out instead of abbreviating - "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)."
it is very tough to follow.
Posted By: Truffle Royale

Re: To File or Not to File ??? - 02/09/15 02:55 PM

I think I understand your shorthand and I agree that you didn't have to report last year. But by March 1 of this year you do have to report the three purchase and one refi loans you did in 2014.
Posted By: Dan Persfull

Re: To File or Not to File ??? - 02/09/15 03:54 PM

They have no reporting responsibility for loans originated in 2014. These loans, made as of 12/31/14 (the preceding December 31st), makes them a covered institutions for loans they originate in 2015, reportable 3/1/16.
Posted By: Princess of Power

Re: To File or Not to File ??? - 02/09/15 05:51 PM

In other words:
Loans originated in 2013 due to purposes = NO HMDA reporting by 3/1/14
Loans originated in 2014 due to purposes = HMDA reporting for LOANS originated in 2015 by 3/1/16
Posted By: Dan Persfull

Re: To File or Not to File ??? - 02/09/15 06:02 PM

If you made no qualifying loans 2013 then you would not be a covered institution in 2014 therefore you would have no reporting requirements for the loans you originated in 2014.

The qualifying loans you made in 2014 qualifies you as a covered institution; and beginning on 1/1/15 you need to start collecting the applicable information for covered applications received on or after 1/1/15. This information will be placed on your LAR and reported on or before 3/1/16.