Regarding HMDA, we have two different answers as to what defines a Bridge loan. They are basically the same answers with one exception: if the loan is secured by BOTH dwellings (existing one and one to be purchased); OR if the loan is secured by ONE dwelling (either existing or one to be purchased). As I said, I understand consistency is the key to remaining violation free in this area, but again, I would like to know how the majority views this detail of a Bridge loan.
Applicant wants to take equity out of their primary residence at 123 Main Street in order to purchase a secondary residence at 456 Washington Street, using the Main Street as Collateral. Which property should we report on the HMDA LAR?
During my most recent BSA/AML report to the board, there was discussion regarding the number of cases/investigations we conduct versus the number of those that actually result in a SAR filing. The board asked if I could compare our percentage of filings with other banks. I'm not certain that there is a good way to do this comparison due to the many variables in each bank and how they address those variables. Do you have any advice how to properly address the question?
We use a cross collateralization-cross default clause in all commercial loans. If collateral includes 1-4 family residences, in a refinance, is the loan HMDA reportable?
I have a HMDA question. I have loan that is to purchase an apartment complex, 60 apartments in 5 separate buildings. Do I report this all at once or do I report each building separately?
A loan to an individual for business purposes that is collateralized with a hypothecation agreement and a security deed on another person's (not a borrower) one to four family dwelling, HMDA reportable?
When a loan is secured by two properties, which one do I list on the LAR? A customer's existing home and the home he is purchasing are being used to secure the loan.
A lender approved a mortgage loan and did not gross up the customer's social security income, so for HMDA reporting, I used what the loan officer came up with in determining his income. Now, upon reviewing my quarter-end HMDA reporting, the HMDA compliance officer claims the social security income needs to be grossed-up and that I should change my HMDA LAR to reflect this change. Is this correct? I thought that I was to report my HMDA according to the data used to approve the loan application. Please clarify this for me.
Are we required to report HMDA information on a loan where we are taking a security interest in a lot which is owned by the borrowers, but not in the mobile home that sits on the property? The mobile home is being purchased on contract from an individual, and is not in the borrower's name. Does RESPA apply to this loan? The purpose of the loan is bill consolidation. We plan on documenting the file showing the purpose, and do not think either of these regulations will apply.
Is purchasing a time share, using the person's primary residence as security, HMDA reportable?