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HMDA Loan Reporting

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Question: 
Regarding HMDA loans: if a loan is considered to be a home improvement loan if the funds are used to finance improvements, but not so if the proceeds pay the borrower back for improvements already made, then how would we report a loan made for improvements that are made in the past if the borrower is not getting the money back, but rather paying off the credit card and/or LOC used to finance the improvements? The improvements have already been made, but the proceeds are not paying the borrower back directly and are in a way, still financing the improvements.
Answer: 

The proceeds of your loan are being used for debt consolidation, not home improvement, and this would only be reportable if it meets the definition of a refinancing.

First published on BankersOnline.com 11/01/10

First published on 11/01/2010

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