HMDA and transitory dwellings
06/12/2017
Our borrower owns a home that is used only for a few days here and there during the year. Is this a transitory residence?
You can reach Kathleen via email at kblanchard@keycomplianceservices.com,
06/12/2017
Our borrower owns a home that is used only for a few days here and there during the year. Is this a transitory residence?
03/19/2017
Our bank has a consumer line of credit product that is payable on demand with no set maturity date but there is an annual review. During the annual review, a credit report is pulled. We do not utilize risk-based pricing and have chosen to use the Credit Score Disclosure Exception Notice. Is this notice required in this case?
02/12/2017
My question is in the area of HMDA reporting. An application for a refinance (replenish reserves and capital) on a multi-family residence with the subject property having a existing lien was received, reviewed and denied. The only reason for denial was that the borrower did not own the subject property. Per "HMDA Reporting Getting It Right!," I believe we should report the loan as a refinance since there is an existing lien. With this scenario of having a borrower that does not own the subject property, I would like to verify if it is reportable and how?
01/08/2017
What is a warrant and how is it handled? This is a question about a loan to a fire department to purchase a truck.
01/01/2017
My customer is purchasing a large RV which will be his permanent home. Is this HMDA reportable?
12/25/2016
If a loan is to purchase a single family dwelling that will be rented out for vacation rentals, is this loan HMDA reportable?
12/18/2016
Our collateral consists of an apartment complex made up of 4 units per building, each with a separate address. Is this a multifamily secured loan?
12/18/2016
Is a dwelling that will be converted to a non-residential use after sale a dwelling for HMDA purposes? The seller will be residing in the property until right before the loan closing.
12/11/2016
Under the 2018 HMDA rule, does a manufactured home community need to have actual manufactured homes securing the loan?
12/04/2016
I keep getting requests from lenders wanting to do an unsecured business loan taking real estate as an abundance of caution. I am fairly new to the bank and I have told them on several occasions that we should not be doing this, but I am getting resistance and the lenders are trying to tell me that the bank has always done this. Can you tell me if there are any situations where it is acceptable to do this?