HMDA Loan Amount - Non-originated

Posted By: fretzer

HMDA Loan Amount - Non-originated - 02/15/18 03:33 PM

In regards to the reported loan amount on the HMDA LAR - I understand 1003.4(a)(7) states "if" the applicant accepts the counteroffer report the amount granted, but what happens when a new LE is sent due to a "change of circumstance" because the appraisal may have come in lower than expected?

If there's a confirmed receipt of the revised LE; the applicant does not return a signed copy but continues providing requested information and the loan is ultimately denied due to other factors, how should the loan amount be reported? Appreciate feedback.

Paragraph 4(a)(7).

1. Loan amount--counteroffer. If an applicant accepts a counteroffer for an amount different from the amount initially requested, the institution reports the loan amount granted. If an applicant does not accept a counteroffer or fails to respond, the institution reports the loan amount initially requested.

2. Loan amount--multiple-purpose loan. Except in the case of a home-equity line of credit, an institution reports the entire amount of the loan, even if only a part of the proceeds is intended for home purchase or home improvement.

3. Loan amount--home-equity line. An institution that has chosen to report home-equity lines of credit reports only the part that is intended for home-improvement or home-purchase purposes.

4. Loan amount--assumption. An institution that enters into a written agreement accepting a new party as the obligor on a loan reports the amount of the outstanding principal on the assumption as the loan amount.
Posted By: ComplyCycle

Re: HMDA Loan Amount - Non-originated - 02/20/18 09:47 PM

On non-originated loans, the original loan amount requested must be reported. See HMDA GIR A-2.