[Mary Frances]

We did a 1 year Bridge loan for a borrower in order to help them purchase a new home, which is not HMDA. The new home is being financed through secondary market (we do not underwrite these loans). The note for the Bridge loan was sent to the underwriter. The underwriter informed us the term had to be at least 5 years. The loan was then modified/extended for 5 years in order to comply with the secondary market guidelines. We have a difference of opinion that the loan should now be reported as HMDA because it is no longer a “Bridge” loan; however we did not replace the existing loan or any documents.

[rcooper]

Trying to understand your situation better…Can you provide more detail on the bridge loan?

[Mary Frances]

We did a 1 year bridge loan secured by a 2nd mortgage on the borrowers current home (not HMDA). The proceeds were used for the purchase of a new home being financed through secondary market. Secondary market underwriters requested the terms of our loan so a copy of the note was sent to them. The underwriters sent us a condition that our loan had to be for at least 5 years. Since our bridge loan had already closed and we did not want to hold up the secondary market loan closing we did an extension on our loan to extend the maturity date out to 5 years (underwriters were fine with this). I do not think the extension is HMDA reportable since we did not replace and satisfy a mortgage. However, we have a difference of opinion because some of us feel since the loan now has a 5 year term and not really a “bridge” loan it should be reported as HMDA.

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