[shelia]

We have some confusion as to whether this is a reportable transaction(s) or not. We currenty have financed a loan with 5 investment dwellings. The customer has applied to finance each dwelling individually, hence 5 new transactions. Individually these loans will not satisfy and replace the original loan but as a whole they do satisfy and replace the existing loan. Would each new loan be HMDA reportable? Are we overthinking this??

[jholzknecht]

You are not over-thinking anything. I am not aware of anything in HMDA, Regulation C, the HMDA Guide that directly addresses this issue. I agree with your analysis – none of the loans individually satisfies and replaces the existing loan, but as a group they do meet the definition. IMO these loan are refinances, but my opinion doesn’t really count. You may want to run this by your examiner.

[jholzknecht]

A couple divorces. She purchases his interest in the house they previously owned jointly. Is this reported as a purchase or a refinance?

If the deed is changed I view it as a purchase loan.

What are your thoughts?

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