Skip to content

New HMDA: Borrowed definitions can cause problems

Question: 
What types of definitions are borrowed from Regulation Z for use in HMDA filing under the new (2018) rules?
Answer: 

A “simple” example is the definition used for balloon loan. For any consumer or business purpose loan, open or closed end, HMDA will use the definition from the integrated disclosures of Regulation Z (TRID). This means that a balloon loan is defined as any loan with a payment that is more than two times a regular periodic payment. This will be a surprise to commercial lenders.

Learn more about Kathleen’s webinar HMDA Rule Revisions: Deep Exploration .

First published on 05/08/2016

Filed under: 
Filed under lending as: 

Search Topics