12/08/2008
A couple bought a home for their son and took out a HELOC secured by their own home. The home purchased for the son was titled in the son's name when purchased. Now the son wants to do a loan secured by that home to pay his parents back. Would this be HMDA reportable? I don't think so because the son already owns the property.
11/24/2008
My studies indicate lines of credit are optionally reported (we do not report). Most of the writings seem to equate lines of credit with home equity lines of credit with no distinction between closed-end and open-end. Are there different reporting rules for open-end and closed-end lines of credit?
07/14/2008
I have read the following statement under Reg B staff interpretations of 202.13 (#5) "an application for open-end home equity line of credit is not subject to this section unless it is readily apparent to the creditor when the application is taken that the primary purpose of the line is for the purchase or refinancing of a principal dwelling". To me that means that if an applicant applies for a HELOC with the intention of purchasing or refinancing their home that we (the lender) should gather government monitoring information. Am I understanding correctly? If I am, what is the creditor supposed to be doing with the GMI? For HMDA we report the GMI on the HMDA LAR, but there is not a Reg B LAR to my knowledge.
04/07/2008
If part of the proceeds of a refinance loan are to recoup home improvement costs would the purpose be home improvement?
03/03/2008
I would like to know if the following scenario is HMDA reportable. We have a member that currently has an unsecured home improvement loan with us and now he wants a second mortgage to pay that loan off. Would the new second mortgage that will be paying off an unsecured home improvement loan be HMDA reportable?
10/22/2007
When tracking for census tracts, do we tract based on where a borrower lives or where a borrower is purchasing an additional property? Are we tracking the borrower or the property?
07/16/2007
What would cause a commercial loan be HMDA reportable in 2004 or 2005 with a guarantor as a co-applicant?
06/18/2007
A customer applies for a fixed rate home equity loan which will be the first and only lien on the property. Do I need to collect government monitoring information?
05/21/2007
If you have a home improvement loan or a refinance that involves over 25 acres is it HMDA reportable? I realize the purchase of a residence with over 25 acres isn't reportable, but I was thinking home improvement or refinance is reportable.
04/09/2007
I have a motel loan with 12 units and an office/home for the manager to live in and both are on the same property. The office/home is not worth 50% of total loan amount. Does HMDA apply?