When reporting the rate spread for HMDA on a construction-permanent loan, should the rate spread for the construction phase be reported or the
permanent phase, which will take place a year later?
I have a loan secured by a dwelling and a savings account. According to the HMDA commentary, I include the savings account when computing the CLTV.
Okay, that's clear enough. My question is, do I include the savings account in reporting property value? Do I only include real property?
We have a borrower that is using their primary residence (that does not have an existing lien) to purchase a second home. If I am understanding Reg C
correctly, I would be reporting the loan as a purchase because that is what the funds are being used for. Would I then report it as a primary residence
because the property that will have the lien is their primary residence or would it be a second home because that is what the funds are being used for?
For HMDA reporting purposes: An applicant's demographic information is obtained at time of application via an online application process and the
data collected is the information input onto the HMDA LAR. But if the applicant changes the demographic info at consummation (at the title
company) do we change the data on the LAR from the data collected at application to the data collected at consummation?
Are all transactions that are HMDA reportable counted toward the thresholds?
How are lines of credit that do not revolve treated; are they open-end or closed-end?
As to a loans HOEPA status, are second homes and vacation homes considered
not applicable for HOEPA which would make the status code 3 on the HMDA LAR
What open-end lines are counted for the HELOC threshold?
What do we report for property value and loan to value if two properties secure the loan, but one was taken in an abundance of caution (AOC) and treated as AOC for the appraisal requirements?
Is there a difference in reporting the total units for two single family homes vs a duplex where both units secure the loan but are contained in the same “property”? Sometimes the duplex will have separate deeds for the units, other times it is on one deed if there is one owner.