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#218225 - 07/30/04 04:09 PM Is this HOEPA?
Anonymous
Unregistered

If a borrower uses the equity in his principal residence to purchase a new car, would this be a HOEPA loan>?

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General Discussion
#218226 - 07/30/04 04:13 PM Re: Is this HOEPA?
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,691
Bloomington, IN
If it exceeds the thresholds, yes.

The only loans exempt under 226.32 are Residential Mortgage Transactions, Open-end LOCs and Reverse Mortgages.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#218227 - 07/30/04 04:19 PM Re: Is this HOEPA?
Anonymous
Unregistered

Would this be HMDA reportable too?

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#218228 - 07/30/04 04:25 PM Re: Is this HOEPA?
Anonymous
Unregistered

Nevermind, I found the answer in another post. This would only be a HMDA loan if it was a refinance and the proceeds were also used to buy a car in addition to home improvement. Correct?

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#218229 - 07/30/04 04:41 PM Re: Is this HOEPA?
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,691
Bloomington, IN
Your dwelling secured loan would not be reportable unless :

It is satisfying and replacing an existing loan secured by a dwelling to the same borrower;

If any proceeds are for home improvement;

If any proceeds are to purchase a dwelling.
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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