Where can I find a regulatory reference as to the HMDA reportability of loan modifications?
I’m talking about a situtation where the loan terms were changed but the original Note and Mortgage were not satisfied and replaced. In the situation I’m questioning, there was a “Change in Terms” to the Note and a Mortgage Modification to account for the additional advance of funds ($2500) but there was no new loan created.
I couldn’t tell you where to find it, I’ve looked at Reg C and HMDA’s GIR. However, the definition of a refinance is “any
dwelling-secured loan that replaces and satisfies another dwelling-secured loan to the same borrower”. So if you’ve got a modification with new money then you should be getting a new note and new deed of trust. (I’m not saying that you’re going to have a new note number.)
So are you questioning if this loan is actually reportable? In this case, I’d say yes.
I’m not sure that this is where you’re going with your question though.