Purpose to Reimburse for Previous Purchase-HMDA

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Question:

We have a residential (investment) real estate secured loan with the purpose being to reimburse the borrower for PREVIOUS purchase and PREVIOUS improvements of the property. We are debating over whether it is or is not reportable. What do you think?

Answer:

None of the loan proceeds are being used for a home purchase, home improvement of refinancing. The proceeds are being used to replenish the borrower's personal funds. The loan is not reportable.

First published on BankersOnline.com 4/1/13