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New Loan w/Property from Unsecured-HMDA?

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Question: 
Our customers own a KOA campground. They wanted to borrow money to build a home on the campground for the manager of the campground to live in. We gave them a short term unsecured loan to build the home. When the unsecured loan matured we gave them a new loan secured by the property which paid off the unsecured loan. Is the new loan subject to HMDA reporting?
Answer: 

No, because it does not meet the definition of a home purchase, home improvement or a refinance.

First published on BankersOnline.com 3/11/13

First published on 03/11/2013

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