FRB FAQs-Is this loan reportable: A 12-month construction loan that must be refinanced at the end of the 12-month period? (The loan does not include an option for rolling into permanent financing.)

Compliance > Regulation C - HMDA > FRB FAQs
Q:  Is this loan reportable:  a 12-month construction loan that must be refinanced at the end of the 12-month period? (The loan does not include an option for rolling into permanent financing.)
 
A:  Based on the Federal Financial Institutions Examination Council's (FFIEC) HMDA Frequently Asked Questions (HMDA FAQs),1 a primary consideration for determining if a loan is temporary financing is whether it will be replaced by permanent financing of a much longer term. Therefore, if this loan will likely be replaced by permanent financing by the bank or another lender, even if the loan does not include a permanent financing rollover option, it would likely be considered temporary financing and therefore exempt from HMDA reporting.
 
 

This can be found in - HMDA FAQ#3 of the FAQs.  The Federal Reserve Board FAQs can be found at: https://consumercomplianceoutlook.org/2011/second-quarter/hmda-and-cra-data-reporting/

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