Most Popular Lending Content
HMDA GIR Mixed Use Properties
10/14/2018
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?
Home Equity Loan: Improvement or Cash Out Refi?
10/14/2018
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?
Closed-End Threshold Test: Count Purchased Loans?
10/14/2018
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!
Getting Escrow Statements in Sync
10/14/2018
Doing annual statements is a real pain every month. What can we do to make these easier?
Loan Created in Signers Name-Company Debt
10/14/2018
A customer is signing for a company and owns 25% of the company, if a loan is created in the signers name would the companies debt need to be included in aggregate debt?
