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Is this Renewal HMDA Reportable?

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When doing a renewal, with or without new money, either a term loan or line of credit and the original purpose was either purchase, refinance or home improvement secured by dwelling is it HMDA reportable? The customer is going to sign a new Promissory Note but the account number and the note number is going to be the same.

The account number and note number are not a factor. What you need to determine is if the new Promissory Note satisfies and replaces the existing Promissory Note. If so, then you have a transaction that meets the definition of a refinancing, regardless what the purpose of the original transaction was. Lines of credit are optional reporting. If you do not report lines of credit, then the refinancing of a line of credit is not reportable unless you refinance it into a closed end loan.

First published on 4/16/07

First published on 04/16/2007

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