Reportable or not

I have a loan that is the 2nd DOT to finish the remodel on an I/P, and is a 6M term note. We have the 1st that is an LOC for the purchase and remodeling of the I/P, and it is a 6M term, and of course was not reported because it is a LOC.
So, my question is would this new loan that is being used to finish the remodel be HMDA reportable? I don't think it would, but very unsure!

Thanks.

6M term note? 6 months? Interest only? If so, what are the plans for repayment? Refinance the loan at maturity into long term payments or something else?

We have the 1st that is an LOC for the purchase and remodeling of the I/P, and it is a 6M term, and of course was not reported because it is a LOC.

So you are saying you have a 6 month term note that is open-end credit?

Too cryptic for me!

It's not interest only, it's just the customer needed more money so we are taking a 2nd on the I/P property. I am pretty sure it's not reportable. The loan officer states, and the file shows, the intentions of the customer are unknown at this point, so with it being short term and the other factors I think it's not going to be reportable.

Thanks.

By I/P do you mean investment property? And 6M means 6 months?

The 2nd lien loan is fully (or partially) amortizing? Is it an open-end or closed-end loan?

I/P is investment property, and 6M is 6 months, sorry. And closed-end loan.

Last open question. How will this 6 month loan be repaid?

I agree. If you want us to give comments/opinions/consultation, please be crystal clear. Thanks.

Short term improvement IS reportable. It's not temporary (replaced by a 2nd phase loan). Why do you think it's not reportable?

I am new to HMDA and was trained that we do not report loans that are short term, being less than 12 month, but with the research and the 1st training they have sent me to I....think it might, but told it wouldn't be, so I'm unsure??

We need to know what the plan for repayment is: refinance into long-term financing or simply pay the loan off at maturity. If the loan is designed to be replaced by financing of a much longer term, then it's temporary and not reportable. If the loan is designed with the idea of your borrower paying the loan off in cash at maturity, it's simply a short term loan that would be reportable.

Short Term and Temporary are 2 different things. There is no term for Temporary financing and you cannot say a loan of less than X is temporary. You report short term loans. You do not report temporary loans.

Read §1003.4(d)(3) where it states:
A financial institution shall not report… Temporary financing (such as bridge or construction loans)…

Also, read the HMDA FAQ-Loan Purpose at the FFIEC.gov website where it states, in part:
A loan is not temporary financing merely because its term is short. For example, a lender may make a loan with a 1-year term to enable an investor to purchase a home, renovate it, and re-sell it before the term expires. Such a loan must be reported as a home purchase loan. See §1003.2(h).

David, i'm just concerned that Catm might be using the term "short term" simply because the loan term is, well, short....IOW, it might actually be temporary financing and she is calling it "short term".

Thank you very much.

Thank you very much.