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When two notes are cross collateralized (one note is secured by vehicles and vacant land and the other note is secured by a mortgage on a 1-4 dwelling), does the refinance of the note secured by vehicles and vacant land constitute a HMDA-reportable loan? When determing if it was HMDA-reportable, I was considering both the vehicle-secured note and the cross-collateralized mortgage-secured note to determine if it met the defintion of purchase, home improvement, or refinance under HMDA. Could you please confirm if I am considering these notes appropriately?
When examining cross-collaterializing notes, would it make any difference if both notes were secured by mortgages on improved property? In that case, my determination on which property to report on the HMDA LAR would be based on the property wtih the hightest appraisal value.
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