[Mary Beth Devillier]

Scenario: Loan #1 – Consumer bridge loan secured by their Primary dwelling to purchase new dwelling, interest monthly for 12 months.
Loan #2 – Refinance Loan #1 as original primary dwelling has not sold. Officer classified dwelling as secondary residence for HMDA reporting. This to me is not secondary residence, but now has
become investment property to the consumer. I do not feel it is individual for business purposes as well, but should be classified as a consumer loan secured with investment property now. Am I on
the right track?

Topic

[pparks]

Loan #1 – Bridge Loan? Is this basically a short-term cash-out refinance of their primary to purchase another home? If so, doesn’t seem like a bridge loan…guess I may need more facts?

Loan #2 – You are on the right track. I feel this should be classified as a HMDA reportable investment (at least in most cases) Is this loan being sold to the secondary market? If so, how would they classify it for the transaction? Are they living in the home for any period of time AFTER the transaction?

[Mary Beth Devillier]

Loan #1 – We put a 2nd lien on their primary dwelling at the time to purchase a new dwelling. We did classify as a bridge loan. This loan was to be paid off by the sell of their home.

Loan #2 – We had to refinance Loan #1 as it matured and the home did not sell. It is still on the market to sell. They have moved into their new home and the officer is classifying as secondary residence
on the home with the mortgage. This loan will not be sold in the secondary market, will remain on our books until the sell. These two houses are within the same subdivision, so to me this is investment property for consumer purpose.

[Kimberly Boatwright, CAMS, CRCM]

Following the conversation.

[Author]

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