04/15/2013
For HMDA reporting is a multifamily (5-units) structure considered to be five apt buildings or five individual dwellings in the building?
04/08/2013
We have a commercial loan. The funds originally were used to finance business assets. (Collateral is business assets and a 2nd on the guarantor's home). We have refinanced the loan. Is this HMDA reportable because of the guarantor's home even though the original funds were used for business purpose?
04/08/2013
Are commercial loans that are purchased from another bank as a Participation Loan with only a portion of the total loan purchased subject to HMDA reporting by Participating Bank when secured by rental homes, etc?
03/25/2013
We have been getting a lot of applications for purchasing short sales. These deals take months to go through the process. How do we handle these for HMDA reporting since they take so long for the approval of the short sale from the bank that owns the property?
03/04/2013
It is my understanding that with small farm loans, the shop headquarters is to be use for the census tract number. If a loan is for farm equipment or something that will be used on the farm, is the headquarters census tract used for that too or can the farmer's residential address be used for the census tract number?
03/04/2013
The Fair Credit Reporting Act requires that each applicant (assuming there is a co-applicant) receive an FCRA adverse action notice in the event of an adverse action. Assume that there is a joint application for an installment loan, not secured by real estate (auto loan for example). The loan is denied because after a review of the credit reports of both applicants, the primary applicant previously filed for bankruptcy and the co-applicant has delinquent obligations with creditors. Should each separate notice provided to the applicant and co-applicant only list the reasons specific to their own credit history? In other words, should the applicant's notice only reference the bankruptcy and the co-applicant's notice only reference the delinquent credit obligations? My reasoning for feeling this way is that 1. it protects the privacy of the applicant and co-applicant and 2. it will better inform the applicant and co-applicant of what specific reasons were used in their denial so that each individual may correct them in order to secure the credit in the future. I understand only one would need an ECOA notice but my concern comes specifically from FCRA notice requirements.
02/25/2013
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?
01/07/2013
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?
01/07/2013
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?
11/12/2012
Is the birth date of the applicant required to pull a credit report?