Answer:
It is important to delve into the detail of the transaction to determine whether it is HMDA reportable. While modifications are not HMDA reportable, there is an exception for NY CEMA transactions, which can be used in many types of transactions. Also, a construction loan that “automatically” converts to permanent financing is not excluded as temporary financing. For that reason, it is important to understand the financial institution’s practices and whether your modifications from construction to permanent financing are effectively the equivalent of a construction/permanent loan.
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Learn more about Kathleen Blanchard’s webinar
Extensions of Credit and the Bigger HMDA Picture - Identifying Reportable HMDA Transactions
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