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Good morning. We are considering rolling out a new product in the next few months and I wanted to get some feed back concerning HMDA. This is a 12 month consumer note, that can not be renewed, refinanced, or extended at maturity. At maturity, the note will either be paid off or placed on principal and interest payments. This product will be secured by either the individual’s principal or second home. The note is a draw line of credit for home improvement purposes. While all this leads me to believe this is a HMDA reportable loan, language in our deed of trust indicates this loan is for “temporary financing purposes only” which plants a seed of doubt. I don’t believe this constitutes the temporary financing discussed in the regulation which I believe concerns construction notes. My other question is, at maturity, if the note is not paid off, will each succeding note be a reportable refinance? Again, I think this so, but I would really like to get a second opinion. Thanks for your help. Have a good day.
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