[tressa]

Let’s say there is no recorded lien. Just an owner-finance agreement between the seller and purchaser. If this debt is paid in full, and it’s in the same borrower name, would it be considered a refinance for HMDA purposes?

[tressa]

Yes, there is a recorded lien.

[tressa]

Please excuse the typo! There is also a washer/dryer.

[tressa]

I am not sure if anyone is living in the pool house. It’s a detached building that is a large room with a kitchen and dining area, full bathroom, and one small room that could be used as a bedroom. There is always a washer/dryer. I don’t think the homeowner has plans to rent it. It’s next to their swimming pool which is located behind their main house.

[tressa]

Same for borrower requested changes, right? If a borrower request a change that causes the fees to increase, you can only reset tolerance if the fees increase beyond the applicable tolerance threshold (0% or 10%).

[tressa]

Let’s say loan #1 the 6 month loan was to purchase the borrower’s primary residence and remodel and then the borrower makes loan #2 which is another temporary loan with additional money to finish the remodel.

Would loan #2 be exempt from the HPML appraisal rules?

[tressa]

So if the covered HMDA loan is 12 months interest only – variable rate (1% above 4.75-WSJ) – no introductory or teaser rate – and the interest rate can change daily – the following data points should be reported:

Interest Rate – enter 5.750 – the fully indexed rate
Introductory Rate Period – enter 1 – rate is variable and can change daily

Do you agree?

[tressa]

12 interest payments – then coverts to 59 principal and interest payments – then one final balloon payment at maturity

[tressa]

Would the ATR rules not apply if the loan was secured with the new primary residence instead of the borrower’s existing resdience? Same loan scenario only new residence is collateral and not the existing residence.

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