[Angie Cowell]

We are doing a one year consumer loan so the borrower can purchase a new primary residence. We are taking both the new home and the existing home as collateral. When the current home sells, a principal reduction will be made on the loan. Is this loan HMDA reportable? The loan will either be modified or refinanced but that is unknown at the time of application, does that make a difference in determining if it is reportable?

[rcooper]

If the loan is temporary financing (plan to replace with longer term financing) you would not report the temporary loan. If it not temporary you would report it as a purchase.

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