Guarantors to Co-Borrowers Considered HMDA Loan?

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Question:

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?

Answer:

HMDA is applicable to purchases, home improvement loans and refinancings. Who the borrower is (an entity) does not exempt a loan from HMDA. You should be reporting these loans whether a natural person is a guarantor or a co-borrower.

First published on BankersOnline.com 6/6/11