Rate Spread and Commercial Loans Subject to HMDA
12/10/2017
How to we report rate spread on commercial loans and li/nes of credit?
You can reach Kathleen via email at kblanchard@keycomplianceservices.com,
12/10/2017
How to we report rate spread on commercial loans and li/nes of credit?
12/03/2017
Is the investment occupancy category only used for true rental properties?
11/26/2017
We still make loans secured by older mobile homes that are used a principal residences. Should we report for HMDA if the home is a principal residence?
11/19/2017
We merged with another financial institution in 2017 and are confused about the reporting rules. There is an exclusion for loans acquired as part of a merger and acquisition yet there are instructions for how to report. What do we report?
11/12/2017
As a HMDA reporter, can’t we ignore the demographic data collection required by Regulation B?
10/15/2017
Our bank has a small staff that simply handles the HMDA LAR, testing all fields for all portfolios. They are confused by some terms that are new to them, such as ATR. What is HMDA talking about?
10/08/2017
A large part of our HMDA LAR is made up of commercial loans. Do we just report NA for these new fields that borrow loan feature definitions from Regulation Z?
10/01/2017
We have interest only lines of credit in our commercial portfolio. Will those be the ones we flag as having an interest only feature?
10/01/2017
I am trying to obtain a good definition and/or guidance on how to report Revolving Lines of Credit that have been extended and not renewed for a particular year. Example – A customer has a revolving line of credit for $250,000 that originally was executed in November 2014 and is up for renewal in November 2015, however the borrower has asked for a 3-month extension which the bank granted, the amount and conditions are unchanged. For 2015 reporting, can we/should we be reporting/treating the $250,000 as a renewal/extension that took place in 2015? Or not report it as it was an extension and not a renewal according to the CRA quidelines?
09/24/2017
Do we complete the loans costs field and the points and fees field?