HMDA Reporting on LAR

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Question:

The bank made a $1,000,000 HMDA reportable loan in February, then in November gave the borrower another $500,000 under the future advance clause. Borrower requested the additional funds and bank granted the request after reviewing credit, etc. This bank is FDIC regulated. Should this future advance be reported on the LAR as a separate line item under the same loan number as one other regulator previously required or, if not, how should it be reported?

Answer:

I'm confused about the details of this loan(s). If this was an advance under the previously reported loan, then it is not reported on the LAR (again). If this is a new loan, then it is reported.

If the February loan is the only contract, then it sounds like it really was for $1.5 million, not just $1 million. The total loan commitment should be reported, not just the first advance in a multiple advance loan.

First published on BankersOnline.com 2/28/11