Renewed Loan into Single Payment-HMDA Report?

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Question:

I have a commercial loan secured by 2/13 interest (first mortgage) on a house. When this loan was originated, it was an open end line of credit and now has been renewed (new loan number) into a single payment loan due in one year. Is this a HMDA reportable loan? The source of repayment for the loan is business income.

Answer:

How do you secure only 2/13 of a dwelling?

Regardless, this is a reportable refinancing. You are satisfying and replacing a dwelling-secured obligation with another dwelling-secured obligation to the same borrower.

The new closed-end loan does not qualify for the open-end LOC optional reporting and it is not temporary financing. It's short term financing.

First published on BankersOnline.com 7/16/12