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#411640 - 08/22/05 06:27 PM HMDA - Additional Advances via Additional Note
SJB Offline
Diamond Poster
SJB
Joined: Jun 2002
Posts: 1,210
California
We make combined construction-to-permanent home loans. Sometimes a loan will close and be funded and later an additional advance is approved. In this situation we do an additional note for the additional amount and modify the mortgage to reflect the additional advance. If both events occur in one year, should this be reported as:
a) one loan for the original amount,
b) for the amount of the original loan plus the additional advance, or
c) should it be reported as two home purchase loans?

What if the original loan is funded in one year and the additional advance occurs the next year?


Thanks!
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Lending Compliance
#411641 - 08/22/05 06:51 PM Re: HMDA - Additional Advances via Additional Note
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,763
Bloomington, IN
Quote:

In this situation we do an additional note



You are making a new loan secured by a dwelling. If it meets a HMDA reporting purpose it would be reported as a separate entry on the LAR.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#411642 - 08/22/05 08:21 PM Re: HMDA - Additional Advances via Additional Note
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,765
Central City, NE
I agree with Dan. I also believe that it requires all new RESPA, TIL, etc.

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#411643 - 08/22/05 11:11 PM Re: HMDA - Additional Advances via Additional Note
SJB Offline
Diamond Poster
SJB
Joined: Jun 2002
Posts: 1,210
California
David - I like the first half of your answer, can I ignore the rest?
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#411644 - 08/23/05 01:51 PM Re: HMDA - Additional Advances via Additional Note
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,763
Bloomington, IN
Quote:

can I ignore the rest?



Just in case you weren't joking ( gave me an idea you were) and for the benefit of others, no you can't ignore the second half of David's answer. Creating a new note is creating a new loan, and all applicable regulations and disclosures will apply.
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The opinions expressed are mine and they are not to be taken as legal advice.

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