For those second lien products that are forgivable downpayment assistance grants, or bond loans, is there anything special we need to know about reporting these?

As far as I know, they are reported just like any other second lien, it's just that the interest rate might be 0% and the payments (since they are interest only, or maybe nothing at all), are reported just as they appear on the CD. I am not familiar with all the various bond programs, but wouldn't these be reportable?

If you are making the credit decision on these loans, then:

4. Second mortgages that finance the downpayments on first mortgages. If an institution making a first mortgage loan to a home purchaser also makes a second mortgage loan or line of credit to the same purchaser to finance part or all of the home purchaser's downpayment, both the first mortgage loan and the second mortgage loan or line of credit are home purchase loans.

What if the lender is not making the first mortgage, and is only making the 2nd mortgage? Are these only reportable if the lender also makes the first.

There are first mortgage programs where our portfolio downpayment assistance product is made behind the first.

It is a second lien mortgage - reportable like any other second lien mortgage if you are making the credit decision.

Okay - makes sense.

Since the interest rate on these are typically zero (0%), would we report NA for rate spread, or zero?

For the bond programs, where there is no rate at all, would we report these as NA in the interest rate field, or zero?

Circling back to this topic.

I want to be sure we are properly reporting bond loans for HMDA.

For Florida Housing DPAs, If the 1st lien is approved under our delegated authority, the DPA is automatically included—there is no separate approval, documentation, or AUS process. Also, there is no rate lock. Funds are "reserved" when we set the date on the first lien with Florida Housing. While no separate decision or underwriting is required for the 2nd lien, disclosures are necessary and would be retained in the 2nd lien loan file.

Would we report these since we didn't "make the decision" on the bond loan?