I have a loan that is secured by 1-4 dwelling; the purpose is to consolidate two loans, one is secured by the same dwelling and the other is unsecured; since both loans are not secured by real estate would this be HMDA reportable? Thanks for any help understanding this.

This is a reportable refinancing.

A refinancing is any dwelling secured loan to the same borrower that satisfies and replaces another dwelling secured loan regardless what any additional proceeds may be used for unless the additional proceeds are used for a home purchase or home improvement and then they take precedence over a refinancing.

Please forgive my questions, but I want to understand. Since one of my loans being consolidated is secured but the other one isn't and the new loan is secured that is why it would be reportable as a refinance. Thank you.

You are paying off a secured loan. It doesn't matter what the other proceeds are being used for. In your case, they are paying off an unsecured loan. They could also be buying a car, paying off credit cards, whatever. It doesn't matter.

See page 29 of the GIR.

http://www.ffiec.gov/hmda/guide.htm


Refinancing. A refinancing is any dwelling-secured loan that replaces and satisfies another dwelling-secured loan to the same borrower. The purpose of the loan being refinanced is not relevant to determining whether the new loan is a refinancing for HMDA purposes. Nor is the borrower’s intended use of any additional cash borrowed relevant to determining whether the loan is a refinancing, though the borrower’s intended use of the funds could make the transaction a home improvement loan or a home purchase loan. See the definitions of “home purchase loan” and “home improvement loan.” Also see the rule on multipurpose loans on page 12.

Thank you so much for your help.

Thank you so much for your help.

Thank you so much for your help.

Wow, now that is one grateful person.

I was grateful, but I think it was more a lack of computer skills that got me!!!!!!