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HMDA Report a Refinance of Commercial Loan?

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Question: 
My question is about a refinance of a commercial loan. The loan is secured by customers personal dwelling; the original purpose was to finance his business. Now we are refinancing the loan and since it is secured by his home, some say we need to report HMDA and others say no because the original purpose was not to finance his home but his business. Do we report?
Answer: 

Yes, this definitely is to be reported as a refinance for HMDA. Any loan, regardless of purpose, that is secured by residential real estate and refinances a loan that was also secured by residential real estate and is to the same borrower is a HMDA refinance.

A special carve out was made under CRA when the HMDA refi definition was broadened and encompassed all of these commercial purpose refinance loans secured by residential real estate.

This has been in place for quite some time.

First published on BankersOnline.com 9/19/11

First published on 09/19/2011

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