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Credit Extension for Investment Property

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Question: 
Can you tell me if I need to file a HMDA on the following transaction. I have a loan for a customer who originally started out as a line of credit secured by a one-to-four family investment property. The loan has matured and we are extending the credit for another year. We have been told that this loan is now considered a "refinance", and that we would indeed need to file for HMDA. I was thinking that since it wasn't HMDA reportable to start with we wouldn't do one at maturity.
Answer: 

If you extended the LOC with a new note and it is now a closed-end credit, the loan is a reportable refinancing. If you continued the LOC as a LOC, then it would not be reportable if you do not report LOCs and assuming it is an open-end LOC.

First published on BankersOnline.com 12/06/10

First published on 12/06/2010

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