October 3, 2013 at 2:42 pm EDT
#4020
HMDA Guy 78
Member
I would agree, Robin – my concern is … if the borrower doesn’t sell his other home, and we have to refinance the loan into long-term financing, is there an issue in us reporting HMDA twice on it? Because in that case it would be a refinance for Reg C / HMDA purposes.