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Home Loans & HMDA Reporting

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Consumer is constructing a residence on land already owned, using consumer's own money. Consumer needs more money to finish up (house is almost complete when consumer comes to bank). Bank loans money to consumer and takes lien on house. Is this HMDA reportable, if so, as what? Bank is making 15-year permanent loan - loaning $70,000 on house worth $280,000. Examiner first told bank it was not reportable, then said later it was as a home purchase loan and said bank should have provided early Reg. Z disclosures. HMDA Help said it was not reportable.

I believe that this should be reported as a purchase. This is a good example of the confusion that HMDA allows.

First published on 11/04/02

First published on 11/04/2002

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Filed under lending as: 

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