HMDA Questions - New To Compliance

Posted By: Big Blue Banker

HMDA Questions - New To Compliance - 01/15/10 08:37 PM

I have two HMDA questions...

1.) If a loan is not HMDA reportable at origination (example, using the funds to purchase a car and securing it with your home) and that is refinanced...would that then be HMDA reportable? (Dwelling secured replaced by dwelling secured)

2.) If an obligation is refinanced at the beginning of 2008 and then again at the end of 2008, and is HMDA applicable, would you report BOTH refinances or just one per year?

Thanks!
Posted By: hmdagal

Re: HMDA Questions - New To Compliance - 01/15/10 08:59 PM

1. yes, it's reportable
2. both refis are reportable
Posted By: Big Blue Banker

Re: HMDA Questions - New To Compliance - 01/15/10 09:32 PM

Thanks HMDAgal. I found documentation for my first question, do you know of any place I could get the second question in black and white? Not that I don't trust you! I just need some more backing, haha smile Thanks!
Posted By: Doin it right

Re: HMDA Questions - New To Compliance - 01/15/10 09:36 PM

You may be thinking of CRA when you wonder about a refi the same year.
Posted By: hmdagal

Re: HMDA Questions - New To Compliance - 01/15/10 09:53 PM

Banker Bee, you won't find anything saying you don't report the second refi, so it falls under the regular refi definition. Sorry about the double negative - I hope that makes sense.