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5 Year Unsecured Installment- HMDA Reportable?

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Question: 
Would this five year unsecured installment loan be HMDA reportable? The funds needed for purchasing upgrades on a new construction property which will eventually be their primary residence when construction is complete.
Answer: 

Since it is unsecured, it is impossible to be a purchase loan or a refinance loan, since by definition both of those would be secured by a dwelling. That leaves only Home Improvement. For an unsecured loan, it would only be reportable as a Home Improvement loan if your institution classifies the loan as a Home Improvement loan. If you classify it simply as an unsecured consumer loan, then no, it would not be HMDA reportable.

First published on 03/05/2017

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