May 9, 2012 at 6:53 pm EDT
#2912
Anonymous
Inactive
This sounds like a HELOC to me. I’d first find out if that’s something your institution reports. We don’t, therefore this wouldn’t be a reportable loan. We don’t even offer these types of products.
I researched a little bit on BOL (shhh, don’t tell anyone) and here is a link with an answer. HMDA’s GIR really didn’t specifically say anything about the definition of what temp financing is.
https://www.bankersonline.com/compliance/guru2008/gurus_comp022508c.html
Also you had asked about reporting each succeeding refinance? Yes. I would, but I’d check to see if this would be a modification/extension first because that can get a little iffy as to reportability.