01/22/2023
I have a general question about Texas Home Equity law and HMDA reporting. If under Texas law, a home equity loan is considered a refinancing or cash out refinancing regardless of whether the new loan satisfies an existing dwelling secured debt, can that be reported as a refinancing or cash out refinancing on the HMDA LAR?
To my understanding, state law does not impact the reporting of loan purpose under HMDA rules. If a new loan does not satisfy an existing dwelling secured debt, should it be reported as refinancing or cash out refinancing?
I’m specifically referring to the Texas A6 Home Equity loan product. Under Texas law, this product is always classified as refinancing or cash out refinancing regardless of any other definition of refinance.
09/18/2022
For HMDA purposes, when you have multiple properties as collateral, are all properties included in the value even though only one address is required?
11/28/2021
Why use the Rate Spread Calculator?
07/18/2021
When populating the collateral address for consumer closed-end, real estate secured loans (TRID), is there an industry best standard for WHERE we obtain this address from? I know that it must always include the zip code, and a location (if an address via US Postal Service is not available), but I'm curious if there is an unspoken standard of what document this is best obtained from, such as the counties property record card, the written evaluation provided to us from a certified appraiser, borrower attested to, etc.
09/03/2017
I attended a seminar last week and I discovered that our bank, which I thought was approving and selling loans, was actually acting as a broker. Upon speaking to the primary loan officer for these loans I found out that we do not do any of the underwriting for these loans, nor do we make the credit decision. The purchaser is putting these loans on their LAR (as they should), but so have we. I have been working here nearly a year now and just found that information out and I am upset with myself for not knowing this information before now. I looked at our LAR from last year and see that nearly half of the loans on the LAR should not have been reported as they were these brokered loans. It is the same story as far back as 2014. Do we
need to go back and re-submit the LAR(s) or can we proceed as normal? Are we looking at penalties? I am really shocked at this news. After several exams and outside audits, this was never discovered until now. I would really appreciate any tips you can offer.
07/01/2013
HMDA - GMI: two applicants but only one signed the note. What GMI do we report on the LAR?
05/21/2012
I have a loan for 3.7 million secured by 2 commercial buildings and (8) 4-plexes. We split our entries on the LAR. Would I divide the 3.7 million by 8 (the dwellings)and report as 8 entries on the LAR?
02/20/2012
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?
08/29/2011
For HMDA purposes, how is the following loan to be reported? The bank made a construction-only loan with a 12-month maturity. The home was completed as of the maturity date, but the borrower needed time to sell the home. In the interim, the bank makes a loan for 12 more months that we consider temporary financing. At the end of this term, we make another loan to convert the initial construction to permanent financing and report it on our LAR as a home purchase loan. Is this correct? Is there a rule that says the “permanent financing” has to immediately follow the construction loan?
05/30/2011
According to HMDA, should collateral that contains both 1-4 Res and Multi-family property on the same complex be coded as 1-4 or Multifamily on the LAR?