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Imaginary HMDA requirements

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Question: 
Our financial institution originated the permanent financing to replace a construction loan for a new dwelling that was provided by another financial institution. Should we report this as a purchase, even though we did not make the construction loan?
Answer: 

It is important not to try to follow imaginary HMDA requirements. Nothing in HMDA says that the financial institution for the permanent financing must be the same as the temporary financing. We will cover this type of situation and how not to read things into the regulation that can end up wasting a great deal of time that could be spent on real issues.

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Learn more about Kathleen Blanchard Improving HMDA Knowledge and Year-End LAR Preparation webinar.

First published on 10/02/2022

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