Reporting business purpose loans under HMDA
06/30/2024
Must business purpose loans be reported?
You can reach Kathleen via email at kblanchard@keycomplianceservices.com,
06/30/2024
Must business purpose loans be reported?
06/23/2024
2. Can all institutions make use of the HMDA partial exemption?
06/16/2024
1. Where can I find a list of the current MSAs to help determine if we must now report for HMDA (or perhaps no longer are a HMDA reporter)?
10/01/2023
A counteroffer was made, the borrower accepted the counteroffer, and the loan moved forward to closing, but the borrower did not sign the documents at closing and the loan was not originated. Should this application be reported with the original requested values as an Approved Not Accepted, or should we report the counteroffer values as a Denial?
09/24/2023
A consumer purpose loan was originated to consolidate the borrower's credit card debt. The loan is secured by the principal dwelling of the borrower's parents. The parents are not borrowers on the loan and the borrower is not on the deed to the property. What is the occupancy type for this loan?
09/24/2023
For a true preapproval with a final action of "Preapproval Approved Not Accepted" is a rate spread reported, or is NA reported? These loans do not have a property address and would not have received a Loan Estimate.
09/17/2023
We are considering originating assumption loans. Our interpretation is that assumptions are indeed HMDA reportable. However, we cannot locate any specific identifiers within the HMDA reporting database that specifically classifies the transaction as an assumption. Can you provide further guidance? These would be on transactions where indeed there is a new borrower versus those where they are removing an individual due to death, divorce, separation, etc.
09/17/2023
A loan was originated to purchase a subdivision lot. The borrower plans to apply for a construction loan in the next two years in order to build a new home. Does this plan for a construction loan make this lot loan reportable for HMDA?
09/10/2023
A loan was originated that began with an individual borrower but closed in the name of an entity. We initially collected GMI on the individual and reported it as such. Is this acceptable for HMDA?
09/10/2023
For loans to entities (LLC, Corporation, Trust, etc), if the lender calculated a DTI (along with a DSC - debt service coverage ratio), do we report the DTI for HMDA?