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Unsecured Loan

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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?

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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