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.
How should we report income on the HMDA LAR for an application that was withdrawn by the applicant prior to our credit decision?
We have an ongoing disagreement in the office concerning the proper credit bureau reporting of loans, auto and real estate, that are taken out by individuals but are used for business purposes. Do we report these as loans made to the individuals or not report them at all because of the business purpose?
We have a business entity purchasing a property to be used as a rental property. The loan officer obtained personal guaranties. For HMDA we know this is reportable as purchase. My question is about the GMI. Do we report this as business entity not applicable or do we need to report the GMI on the personal guarantees?
HMDA Reporting: I am doing a loan on bare land but it is a home improvement loan to do repairs on the current house they live in. For Property Type, Occupancy, County, Census Tract, and Lien Status which property do I use? Do I use the same property to answer all the questions?
A National Bank customer defaults on an installment loan due to delinquency and the loan is charged off on December 31, 2002. The customer continues to make payments and brings the loan current in 2005. The customer asks the bank to rebook the charged off loan, the bank agrees and a new loan agreement is signed in March 2006. In December 2006, the OCC regulators tell the bank to charge off the new loan (their reason: a bank can not rebook a charged off loan) even though the loan was current and paid as agreed. Since the customer was not at fault and the bank was in error to rebook the loan, how does the bank report the loan to the credit bureau? Do they use the original date of December 2002 or December 2006?