12/18/2022
We have a purchase mortgage application that was approved with all underwriting conditions met. In review of the title run it was discovered the seller could not convey a clear title to the property. We did send the borrower a Notice of Action for Incomplete Application giving 10 days for clear title to be received. For HMDA purposes would the Action Taken be Approved Not Accepted or Denial?
12/04/2022
We have a HELOC that is going to pay off a tax lien on a dwelling. Should the purpose be reported as "Refinance" or "Other" for HMDA purposes?
11/06/2022
This is about HMDA reporting for Loan Purposes under 1003.4(a)(3)-6. I think I might am being too literal in my understanding of home purchase. A customer is getting a loan, using their primary residence as a collateral, making this a refinance. The cash out portion will be funding is to purchase another property as investment rental.
Our line of business is stating this would then be a home purchase because "Purchase" trumps refi. I do not agree. I feel that because they are using the refi loan as the source of funds it stays as a refi. If they were using the other property as collateral then I would agree. In that case it would be a home purchase because they are buying the collateral with the loan.
How should this be coded for HMDA?
10/16/2022
A loan is secured by a rental dwelling owned by our borrowers. The dwelling is rented out for vacations and our borrowers do use it for personal vacation time, but never for more than 14 days in a year. We are having a disagreement whether this is HMDA reportable or not. If reported, what occupany code do we use?
10/09/2022
A credit report and score was ordered but the report did not include a score. Should we report this as score and not a number?
10/02/2022
Our financial institution originated the permanent financing to replace a construction loan for a new dwelling that was provided by another financial institution. Should we report this as a purchase, even though we did not make the construction loan?
10/02/2022
If we accidentally deny a loan that has already been withdrawn by the borrower, prior to our credit decision, how should we handle the reporting of the HMDA data on the LAR? Should we report it as withdrawn per Reg C regardless of the existance of the denial letter, or should we report it as denied because there was a credit decision and letter issued and that's the action taken by the bank?
09/25/2022
Is an ADU a dwelling for HMDA purposes?
09/25/2022
Our HELOCs are variable rate, but don’t have an “introductory rate." The rate is just subject to change on the first business day of every month. Is that reported on the LAR or do we just put NA since we don’t technically have an introductory rate?
Additionally, if we require in the loan contract that the borrower reimburse fees we as the lender paid if the loan is paid off in the first 36 months, does that number need to go under Prepayment Penalty term if we aren’t technically charging a “prepayment penalty”?
09/25/2022
Is a loan to purchase land with a free and clear mobile home as additional collateral considered HMDA reportable? There is no equity being utilized from the mobile home.
