[Anonymous]

Recently attended a training session where it was stated that, if any portion of loan proceeds are going toward home or property improvement that the transaction is reportable. The reg indicates that is only in the case where it is coded as home improvement by the institution. Typically, if the majority of proceeds are being used for some other purpose, we would code it according to that purpose even if a very small portion was going home improvement. We have just become HMDA reportable in 2015 so perhaps we need to change our way of thinking. Is the transaction only reportable if it was coded as a home improvement loan? If the loan isn’t coded as home improvement are we covered?

Topic

[rcooper]

Take a look at page 8 “Transactions to be Reported – Home Improvement”. https://www.ffiec.gov/hmda/pdf/2013guide.pdf

[Anonymous]

We have looked at page 8. It’s not 100% clear to me. It sounds like it’s saying as long as we don’t code a loan as home improvement purpose that it doesn’t need reported unless it meets the purchase or refinance definitions. Do you agree?

[rcooper]

A home improvement loan is: (a) any dwelling-secured loan to be used,
at least in part, for repairing, rehabilitat­ ing, remodeling, or improving a dwell­ ing (or the real property on which the dwelling is located); or (b) any loan not secured by a lien on a dwelling to be used, at least in part, for one or more of those purposes that is classified as a home improvement loan by the institution and is used, in whole or in part, for repairing, rehabilitating, remodeling, or improving a dwelling (or the real property on which the dwelling is located.)

(A) above deals with loans secured by a dwelliA home improvement loan is: (a) any dwelling-secured loan to be used,
at least in part, for repairing, rehabilitat­ ing, remodeling, or improving a dwell­ ing (or the real property on which the dwelling is located); or (b) any loan not secured by a lien on a dwelling to be used, at least in part, for one or more of those purposes that is classified as a home improvement loan by the institution and is used, in whole or in part, for repairing, rehabilitating, remodeling, or improving a dwelling (or the real property on which the dwelling is located).

(A) above pertains to dwelling secured loans while (b) pertains to non dwelling secured loans.

[paulbutler]

Well, I guess a revision of Home Improvement law is needed, as for the current one, its like a misleading to people and that it even propose a partisan agenda in favor of designated agency or the lending themselves. A revision that could easily understand and that supports more aspects for the borrowers.

Regards.
Paul
“works at https://www.sunlinemesh.com/blog/“

[Author]

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