How should we report income on the HMDA LAR for an application that was withdrawn by the applicant prior to our credit decision?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?
In this week's "Weekly Banker Brief," the following QandA appeared: <a href="http://www.bankersonline.com/lending/guru2011/gurus_ldng100311c.html">Cash Out Refi of Investment Property-HMDA?</a> <em>Question: A borrower is getting a cash out refi of investment property. The money is to reimburse their reserves after they bought a house with cash. Is this a HMDA loan? 1 Answer: No. This loan doesn't purchase or improve the dwelling. It also isn't a refinancing. It is a home equity loan that is not subject to HMDA. 2 Answer: I agree, not HMDA but I would contend this loan is subject to TIL and RESPA based on the information provided. It is not for the acquisition, improvement or maintenance of a non-owner occupied rental property and the purpose as stated appears to be for a personal, family or household purpose which would make it a consumer purpose loan.</em> I think that I need a little clarification. I thought that only HELOC loans that are refinancing are not subject to HMDA reporting. If this is a closed-end home equity refinance, wouldn't it be HMDA reportable?
Are loan modifications required to be reported as CRA loans?
In Commercial Lending, an entity as the borrower does not require HMDA. Recently, my loan officers have been making the "usual guarantors" as Co-borrowers instead. Do I now need to complete this as a HMDA loan?
We are making a loan for a $50,000 line of credit to an LLC. They will use it to purchase used mobile homes and place them on vacant lots that they have available. Once they have them in place, they will rent the vacant mobile homes to renters with lease agreements. My questions are: Do we need a flood certification for each used trailer that they purchase with the line of credit? Do we need to fill out a HMDA LAR for each mobile home purchased with the line of credit?
If the original loan application was completed by the customer for home improvement and later changed to other purpose not HMDA reportable, and the application is denied, do you still report for HMDA for the original home improvement purpose? Example, purpose of home improvement marked out and replaced with auto purchase.