[pparks]

During the renewal process, are you taking the residence as collateral as well?

[pparks]

Your advice is accurate…the following is a quote during a HELOC discussion that I heard from another forum in 2018:

“You are mixing acronyms between FNMA and HMDA, which is never a good idea.

If you are making a credit decision based on a HCLTV for FNMA – that equates to a CLTV under HMDA. It is purely the ratio upon which you are relying. How you get to that ratio is a moot point.”

[pparks]

“Enter, as a percentage, the ratio of the total amount of debt secured by
the property to the value of the property relied on in making the credit
decision. Use decimal places only if the ratio relied upon uses decimal
places. The HMDA Platform can accept up to fifteen (15) decimal places
for the Combined Loan-to-Value Ratio.”

§ 1003.4(a)(24),
Comments
4(a)(24)-1 through –
6

What was used in your institution’s credit decision (ask department that underwrites them)? One would imagine they utilized the worst case scenario of the entire HELOC amount (“total amount of debt secured by the property”).

• This reply was modified 4 years, 2 months ago by pparks. Reason: to add notifications

[pparks]

The borrowing entity is that of the employer. The mobile homes are new (2022), so I believe they will be built according to HUD standards. The loans are also secured by the mobile homes themselves.

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