What is a final credit decision for HMDA, after which a customer’s wish to not proceed with the application is not reported as withdrawn?
Our conditional approvals are verbal and there is often not sufficient information in the file for the staff that prepares the HMDA LAR to know what conditions are outstanding. How can we report accurately in this situation?
I'm trying to determine if this commercial loan is HMDA reportable. The borrower is purchasing 295 acres. This mostly vacant land is used primarily for hunting however, there are two dwellings on the property. My question is, can this property be considered primarily agricultural? Referring to Reg. Z guidance on what is considered agricultural, fishing would fit this category but there is no mention of hunting. I wanted to get other opinions as we are leaning towards this being reportable.
Our underwriters do not revisit applications after the conditional approval is issued; why would an underwriting condition make our applications not “fully approved”?
We do not schedule a closing unless all customary closing conditions are met and issue a denial if they are not. Why would we report differently for HMDA than we do for underwriting or creditworthiness conditions?
Is purchasing a shed HMDA reportable? Would it be classified as Home Improvement? Would it matter if it was on a permanent foundation? OR attached to a dwelling?
Under current HMDA rules, if a borrower submits an application for one amount and then requests an increase and a new loan estimate is issued, do we report the original amount requested or the increased amount?
Is a loan to purchase a shed, HMDA reportable as home improvement? Does the shed have to be on a permanent foundation to qualify as a home improvement?
Under current HMDA definition is a mobile home that is attached to real estate considered a 1-to-4 family dwelling or is it manufactured housing? In my opinion a mobile home affixed to real estate is more similar to housing manufactured off site and delivered/affixed to the land than a home that was traditionally stick built on-site. However, a mobile home does not meet the technical HUD definition of manufactured housing either.
We are being told that the CFPB has given an update on construction loans at the time of perm financing. We are understanding it to read that if you do the modification into perm financing (no new loan) it is not HMDA reportable. Does this mean a construction loan would never to reported if this is the case?