HMDA - Number of key fields - Out of the 110 data fields, I need to verify the number of key fields for the HMDA Data Fields. I think that the number is 37 but I just want to be certain.
I have a question related to HMDA 2018, specifically around GMI collection methods. We had some correspondent lenders start using the demographic information addendum in late 2017. What rules would apply to collection method of GMI since the application date was in 2017 but the Demo Info addendum was used?
HMDA: If a borrower says he does do not want to provide information at the time of initial application, but then they complete the GMI information on the 1003 at closing, what information is reported on HMDA? The updated information or the original information provided by the applicant?
Do we count purchased loans for the closed-end threshold test to determine if we are a small filer under HMDA? 1003.3(c)(4) states that the purchase of an interest in a pool of loans is an exempted transaction under HMDA, however I do not think that this includes mortgage loans purchased as a pool of loans. Thank you!
We are brand new to HMDA due to purchasing a branch in an MSA. We will start inputting in 2019. Our question is, if we have a home equity loan (we do not do LOC'S on home loans), it is to refinance existing mortgage and other funds are used for improvements to the property. Would that be a refi, home improvement or cash out refi?
We made a loan to a non-profit for the purpose of acquiring and renovating 10 different properties. Loan is construction - perm. Eight of the properties are residential and the other two properties are commercial. The majority of the square footage (about 72%) of the total square footage of all ten properties is commercial. The two commercial properties are strictly commercial (not mixed use). The commercial properties comprise about 39% of the net collateral value, although the majority of the property values are lender's valuations, and not actual appraisals.
I've looked through the HMDA GIR and do not see where this situation is addressed, unless I've overlooked it. The closest situation I could find addressed mixed use properties. In those situations, it stated it was at the lender's discretion, citing use of square footage or value. So I have square footage leaning to commercial (exempt) and value to residential (reportable).
Would this be HMDA reportable?
If you are not HMDA reportable, do you have to collect GMI for a Home Equity Loan? Not a refinance of purchase money, strictly home equity to consolidate miscellaneous consumer debt and medical bills.
Can mortgage lenders that are not banks or credit unions take advantage of the new partial exemptions?
Does this new exemption affect non-reporters such as those who originated fewer than 25 closed-end HMDA reportable mortgage loans?
Do You Report Co-Signer Information for HMDA?