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Monitoring information

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  • January 23, 2015 at 11:45 am EST #6636
    kmeade
    Participant

    If we are paying off a lien on a rental dwelling, but we are securing the new loan with a lien on their primary dwelling, do we need monitoring information? We are paying off a lien on a dwelling with a lien on the dwelling, just not the same dwelling. Please advise.

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  • January 28, 2015 at 9:27 am EST #6642
    rcooper
    Member

    If you are a HMDA reporting bank and it is a HMDA reportable transaction then you should obtain monitoring information. If not, you are not permitted to collect it under Reg B since the application does not relate to a principal dwelling.

    February 3, 2015 at 12:42 pm EST #6672
    kmeade
    Participant

    Thank you, that is what I thought. We are not HMDA reporting bank.

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