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Refinance Reported as Home Improvement for HMDA?

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Is a 203K refinance reported as a Home Improvement loan for HMDA purposes since rehab dollars are included in the total dollar amount but held in escrow and disbursed later?

HMDA doesn't care when loan proceeds are disbursed. If you have a refinancing plus new money for home improvements, the loan is recorded as "home improvement". Majority of funds doesn't matter.

First published on 11/7/11

First published on 11/07/2011

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