HMDA Refinance - We had a HMDA data integrity review recently and the examiner stated that a loan cannot be recorded as a refinance unless the funds originally went to purchase the home. She referred us to the OCC HMDA handbook for guidance regarding refinancing. I question if the interpretation is being confused by the definition of coverage vs. reporting. In looking at the FFIEC/HMDA FAQs one example is where a home equity line of credit with a junior lien is converted to a term home equity loan. Would this not be reportable for HMDA as a refinance?
Our Bank is not a HMDA reporting Bank. Do we have to collect Government Monitoring Information if we do a loan and file a mortgage on 40 acres that has a home located on the 40 acres?
If a single family rental construction loan is termed out for 2 years with a 25 year amortization and balloon payment, would it be HMDA or considered a short term loan?
Is the birth date of the applicant required to pull a credit report?
What is the definition of improved property versus unimproved property as it relates to HMDA reporting?
We did cash out refinance on a customers primary home. The cash out was used to purchase a second home. I know this is HMDA reportable. I am thinking that a purchase trumps the refinance for HMDA. What I am not sure of is what location to use for the HMDA reporting. Should I use the home being purchased or the home being refinanced? The house being purchased is not securing the loan.
If a person borrows money to do home improvements to a home they do not own but will be renting; is that reportable as home improvement - not owner occupied? We classify and report all of our unsecured home improvement loans.
If we are not a HMDA reporting bank do we have to post HMDA notices in our lobby?
Home equity loan, primary residence is collateral, improvements to rental property is purpose. When reporting for HMDA is it owner occupied or non-owner occupied?
Are we required to disburse a loan on the 4th day of the Rescission period? We have some lenders believing they can disburse the loan any time after the 4th day. As a result, I have run into problems such as when to date the loan on the system and what action taken date to use for HMDA reporting.