HMDA Reporting on an In-house Renewal

Question:

When we do an in-house renewal of a real estate loan secured by a dwelling we get a new note signed, issue a new loan number and do a modification to the original deed that we hold. We do not extinguish the deed and prepare a new one. Would this still be HMDA reportable as and considered a refinance?

Answer:

It sounds like you have a refinance for HMDA. Section 203.2(k)(2) defines "refinance" as: Refinancing means a new obligation that satisfies and replaces an existing obligation by the same borrower, in which . . . both the existing obligation and the new obligation are secured by liens on dwellings."

The deed or mortgage does not need to be extinguished to satisfy the definition.

First published on BankersOnline.com 9/17/07