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Land loan HMDA reportable at renewal?

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  • March 24, 2022 at 5:36 pm EDT #36546
    amarie1126
    Participant

    We did a land purchase loan in 2017. The loan is up for renewal now, and since purchasing the land, the borrower has built their personal residence on the land. Is this now HMDA reportable?

    March 24, 2022 at 5:44 pm EDT #36547
    pparks
    Participant

    During the renewal process, are you taking the residence as collateral as well?

    March 24, 2022 at 5:50 pm EDT #36548
    amarie1126
    Participant

    Well it is attached to our property (legal description). But I do not think our docs will specifically state we are taking a residence. Our docs only reference the land legal description.

    March 25, 2022 at 4:34 pm EDT #36555
    jholzknecht
    Keymaster

    Regulation C requires reporting of open-end lines of credit and closed-end mortgage loans. Both open-end and closed loans must be secured by a dwelling. Your transaction appears to be secured by a dwelling. For purposes of HMDA a refinance is an extension of credit covered by Regulation C, but a renewal is not. You state your transaction is a renewal, which would not be covered. The difference is that in a refinance the existing debt is satisfied and replaced by a new transaction. In a renewal there is no new note; the existing note is modified.

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