[Anonymous]

I posted this in the regular forum HMDA, but got no response. Apologize for the repeat posting.

We do one-time closings for our construction/perms. We have been reporting the loans for HMDA purposes when they go to the permanent phase. We had such a loan close in 2013. The permanent phase was to go into effect on 1/1/2014. We just realized that LaserPro brought it into the HMDA LAR (as scheduled) on 1/1/14; however, the loan paid off in late 2013. How should this be handled? It wasn’t reported in 2013.

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[rcooper]

tstrait,
I apologize that we overlooked your question. Jack will be responding to your question soon. Please watch your initial post for the response.
Thanks for your patience.

[jholzknecht]

A loan is entered on the HMDA LAR in the year in which action is taken. The “date action is taken” may be reported for a construction/permanent loan as either the settlement date or the date the loan converts to the permanent financing. Since your institution choose to use the date the loan converts to permanent financing as the date action was taken, the loan should have been reported in 2014. Since the loan was paid off in 2013 there was no permanent loan in 2014. The loan paid off in 2013 was a construction only loan, which is not HMDA reportable.

[Author]

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