10/16/2022
A loan is secured by a rental dwelling owned by our borrowers. The dwelling is rented out for vacations and our borrowers do use it for personal vacation time, but never for more than 14 days in a year. We are having a disagreement whether this is HMDA reportable or not. If reported, what occupany code do we use?
10/09/2022
A credit report and score was ordered but the report did not include a score. Should we report this as score and not a number?
10/02/2022
Our financial institution originated the permanent financing to replace a construction loan for a new dwelling that was provided by another financial institution. Should we report this as a purchase, even though we did not make the construction loan?
10/02/2022
If we accidentally deny a loan that has already been withdrawn by the borrower, prior to our credit decision, how should we handle the reporting of the HMDA data on the LAR? Should we report it as withdrawn per Reg C regardless of the existance of the denial letter, or should we report it as denied because there was a credit decision and letter issued and that's the action taken by the bank?
09/25/2022
Is an ADU a dwelling for HMDA purposes?
09/25/2022
Our HELOCs are variable rate, but don’t have an “introductory rate." The rate is just subject to change on the first business day of every month. Is that reported on the LAR or do we just put NA since we don’t technically have an introductory rate?
Additionally, if we require in the loan contract that the borrower reimburse fees we as the lender paid if the loan is paid off in the first 36 months, does that number need to go under Prepayment Penalty term if we aren’t technically charging a “prepayment penalty”?
09/25/2022
Is a loan to purchase land with a free and clear mobile home as additional collateral considered HMDA reportable? There is no equity being utilized from the mobile home.
09/18/2022
We have a loan secured by an older mobile home and another security by an older floating home. Are these dwellings for HMDA purposes?
09/12/2022
A year end review revealed 6 errors on your LAR, must we resubmit?
07/17/2022
In order to be considered HMDA reportable as a refinance, does the loan have to payoff an existing loan to the same lender?