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Latest Lending - Reg. C Topics

More Applicants than HMDA Allows

08/06/2023

We have loan that has three applicants. One will live at the property but has no credit. The other two had the credit and income. Since there are only two places to record DOB and Credit Scores for HMDA, which ones do you use?

What's our decision for HMDA?

12/18/2022

We have a purchase mortgage application that was approved with all underwriting conditions met. In review of the title run it was discovered the seller could not convey a clear title to the property. We did send the borrower a Notice of Action for Incomplete Application giving 10 days for clear title to be received. For HMDA purposes would the Action Taken be Approved Not Accepted or Denial?

HMDA "Purpose" when paying a tax lien

12/04/2022

We have a HELOC that is going to pay off a tax lien on a dwelling. Should the purpose be reported as "Refinance" or "Other" for HMDA purposes?

Denied after Withdrawn

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If we accidentally deny a loan that has already been withdrawn by the borrower, prior to our credit decision, how should we handle the reporting of the HMDA data on the LAR? Should we report it as withdrawn per Reg C regardless of the existance of the denial letter, or should we report it as denied because there was a credit decision and letter issued and that's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?

Correcting LAR Omission

06/05/2022

What is the proper procedure if we find a loan was not included in the HMDA LAR for last year? We reported on time by March 1, however, the loan was discovered today. It closed in last November.

Terminology Use - Cash Out

06/05/2022

I used the term "cash out" for a purpose on a loan. Would this term be wrong if I am giving out new money?

HMDA LAR-Residence or Investment

02/13/2022

We are doing a new loan to refinance an existing loan at another bank. The borrower owns the home and the co-borrower lives in the home. The borrower rents to his son. For HMDA purposes do we consider this an investment property or primary residence? To the borrower it is investment property but the co-borrower it is primary residence.

HMDA Purpose Help

02/13/2022

What is the HMDA purpose classification when refinancing a construction loan and converting it to permanent financing - purchase or refinance?

Demographic Addendum Section on URLA

12/12/2021

If an applicant completed the Demographic Addendum section on the new URLA and the loan is not HMDA reportable because it is a construction loan, can the GMI be crossed out, or how should this be corrected?

HMDA Reportable Loan App- Demographic Information

11/28/2021

We have a loan that is HMDA reportable and the borrower is an LLC. On the final application, the demographic information was completed, which it should not have been. Each page of the application references Page 1 of 6, Page 2 of 6, etc. Can we remove the demographic information pages so the last page of the application would read Page 3 of 6? Or, should the completed demographic pages be replaced with blank demographic pages so it still looks like the full application?

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Is this Commercial Mortgage Loan HMDA Reportable?

01/26/2025

We have a commercial loan to an LLC for a purchase/construction loan for 18 months. the loan will be paid off when the property is sold. would this be HMDA reportable? if so, would we report this as a purchase?

Timing of checks for active duty status

01/26/2025

Is the Military Lending Act disclosure required on loan renewals? Does it have an expiration date of when it should be pulled? For example, if the loan was prepared in October, but didn't close until February would I need to pull another MLA status report?

Loan Solicitation Disclosures Needed?

01/12/2025

Currently our Cascade Alerts only provide that a customer did an application for a Mortgage or Home Equity at another bank, but does not provide any details as to what they applied for. If we were to utilize an option with Cascade Alerts on our Mortgage and Home Equity customers where we would be able to know what type of loan the customer applied for at another bank (Mortgage or Home Equity), what would we then be required to provide disclosure wise to the customer?

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