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Refi w/1-4 Family Collateral-HMDA Reportable?

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Question: 
We use a cross collateralization-cross default clause in all commercial loans. If collateral includes 1-4 family residences, in a refinance, is the loan HMDA reportable?
Answer: 

If the old loan and new loan both have a dwelling as collateral, it's a "refinance" for HMDA. It doesn't matter if there's a cross-collateralization clause or not. If you foreclose, you have a dwelling. You can't have the collateral for security purposes, but not have it for disclosure/reporting purposes.

First published on BankersOnline.com 8/20/12

First published on 08/20/2012

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