Refinance Reported as Home Improvement for HMDA?

Question:

Is a 203K refinance reported as a Home Improvement loan for HMDA purposes since rehab dollars are included in the total dollar amount but held in escrow and disbursed later?

Answer:

HMDA doesn't care when loan proceeds are disbursed. If you have a refinancing plus new money for home improvements, the loan is recorded as "home improvement". Majority of funds doesn't matter.

First published on BankersOnline.com 11/7/11