We just started reporting HELOC loans for HMDA. I am having difficulty figuring out rate spread. Do you even need to report rate spread for HELOC loans?
This question is regarding incomplete mortgage applications with an address. (ie: Refi's) Here is the scenerio: Bank approves an application based on the information provided by the consumer, mails the approval letter out which states that based on the application and credit report their loan has been approved subject to the verification of income, assets, and any additional documents deemed necessary from underwriting.
The lender then sits on the file for several months without contacting the customer and then withdraws it stating it is being withdrawn due to no contact.
Should this considered an incomplete application based on the consumer not getting the required documentation to the lender or can it be considered withdrawn since there was no contact with lender since the approval letter?
If an older mobile home is not considered a manufactured home, is it a different type of dwelling for HMDA reporting once we are under the revised 2018 rules?
Has anything changed regarding assisted-living properties under the 2018 HMDA rules?
Will collateral properties owned by a borrower’s relative continue to be reported as owner-occupied under the January 2018 HMDA rules?
Will two four-unit buildings still be reported as a 1 to 4 family property under the revised 2018 HMDA rules?
We have heard that manufactured home communities (mobile home parks) secured only by the land and hookups will be HMDA-reportable beginning 1/1/2018. Is this true? The park owner does not rent out any actual homes, just the sites.
Our borrower owns a home that is used only for a few days here and there during the year. Is this a transitory residence?
The HMDA - Getting It Right manual states if a loan is a home improvement loan as well as a refinancing, an institution reports the loan as a home improvement loan. Does this apply to commercial, multiple-category loans as well, where the proceeds are used primarily to refinance? And if the borrower owns multiple apartment buildings, and uses the residual proceeds to improve a different apartment property, would you still categorize the original borrowing (the one used PRIMARILY for refinance) as home improvement?
Is a commercial line of credit which is being used to purchase and rehab a residential dwelling HMDA reportable when a draw is made?