No Cash Out Loans HMDA Reportable?

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Question:

Questioning if either of these loans are HMDA reportable? Loan #1 commercial loan to refinance an owner contract loan on a 12 unit apartment building, no cash out. Loan #2 a commercial loan to refinance an owner contract loan on a mobile home park, that includes a single family rental, no cash out.

Answer:

In both examples if the old and new loan were to the same borrower and both the old and new loans are secured wholly or partially by residential real estate, the loans will be HMDA reportable as refinances. Cash out has nothing to do with that determination.

First published on BankersOnline.com 6/3/13