[tressa]

When property is taken in an abundance of caution should you report the property value or CLTV?

[jholzknecht]

As a general rule Regulation C, and most other compliance regulations, do not distinguish between a property taken as collateral out of an abundance of caution and properties taken as collateral for other reasons. In either situation the borrower’s home is collateral and could be lost to foreclosure.

The combined loan to value ration and the property value are reported for covered loans, even if the property was taken as an abundance of caution, assuming all of the requirements for reporting are met.

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