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I wanted a second opinion.
In the circumstance that a borrower applies to purchase a mobile home and for some reason we do not obtain the property location where the mobile would be placed (ex -apparent denial and didn’t ask about location) I have stated that this would be HMDA reportable and we should place NA in the property location HMDA fields.I started to second guess myself today on loans where they come in and have a purpose of “purchase mobile home” but don’t have a mobile home selected or list a property location and then we don’t originate the loan–do you think this would more fall under a prequalification and not be HMDA reportable?
Thank you!Under Reg. C, Dwelling means a residential structure (whether or not attached to real property) so it includes a mobile home without the land. As you stated in your first paragraph it would be HMDA reportable and if you don’t have a property location you would report NA.
Under the current rules, your second paragraph describes a “purchase” for HMDA purposes but your reporting rules depend on whether you have a “prequalification” or a “preapproval” program. There is a difference in these two types of programs:
Prequalifications under HMDA is a request by a prospective loan applicant (other than a request for preapproval) for a preliminary determination on whether the prospective applicant would likely qualify for credit under an institution’s standards, or for a determination on the amount of credit for which the prospective applicant would likely qualify. Regulation C does not require you to report prequalification requests on the HMDA/LAR, even though these requests may constitute applications under Regulation B for purposes of adverse action notices. If the loan you described falls under this category, it would not be reportable on the LAR.
To be a covered under a preapproval program, a written commitment is issued under the program and must result from a full review of the creditworthiness of the applicant, including such verification of income, resources and other matters as is typically done by the institution as part of its normal credit evaluation program. If you have a preapproval program, it may be reportable under this option.
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