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Reporting and Interest Only Loan Feature on the HMDA LAR

Question: 
We have interest only lines of credit in our commercial portfolio. Will those be the ones we flag as having an interest only feature?
Answer: 

Interest only for HMDA uses the TRID definition which is defined as loans where “one or more of the periodic payments may be applied solely to accrued interest and not to loan principal; an “interest-only loan” is a loan that permits interest-only payments.”

An interest only line will qualify, but so will a loan or line with just a few interest only payments or the option for interest only payments. Commercial lending will have to learn some new definitions.

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Learn more about Kathleen Blanchard’s webinar
Regulation Z, TRID, and Loans Features – What Do They Have to Do with HMDA?

First published on 10/01/2017

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