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Unsecured Loan

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Question: 
Our bank extended an unsecured loan to a borrower to purchase a home. The unsecured loan was temporary until the mortgage file was ready to close. I'm thinking that the permanent mortgage file should be reported as a home purchase even though we are treating like a refinance. I'm following the same philosophy as the construction to permanent loan files. Is this correct thinking?
Answer: 

The permanent loan is not reportable for HMDA purposes. The proceeds are not being used to purchase a dwelling and it is not refinancing a dwelling secured obligation nor are they being used for home improvement.

For TRID it would be a Home Equity loan.

First published on 10/30/2016

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