With or Without Monitoring Information

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Question:

I have a customer that currently has a real estate loan and an equipment loan with the bank. He wants to combine the loans and get funds to start a new business. Do I give him an application with monitoring information, or without monitoring information?

Answer:

You don't specify whether a dwelling is involved, or whether you are subject to HMDA reporting. Real estate only loans are not subject monitoring information. If the real estate includes a dwelling and if you are subject to HMDA reporting, and you are securing the new loan with a dwelling, you will need the monitoring information because it will meet the definition of a refinancing for HMDA purposes. If you are not subject to HMDA reporting, then you do not need the monitoring information because the loan's purpose is not a refinancing for Reg B purposes.

First published on BankersOnline.com 2/20/06