FRB FAQs-If the bank modifies, but does not refinance, a temporary construction loan into permanent financing, does this loan become a HMDA-reportable loan?

Compliance > Regulation C - HMDA > FRB FAQs
Q:  If the bank modifies, but does not refinance, a temporary construction loan into permanent financing, does this loan become a HMDA-reportable loan?
 
A:  Yes. Comment 203.2(h)-5 explains that when permanent financing replaces a construction-only loan, the loan should be reported for HMDA. In addition, construction-permanent loans must also be reported for HMDA. In essence, the bank has replaced its temporary construction loan with permanent financing through this loan modification. Because it is no longer a temporary loan and has not been previously reported, it should be reported as a home purchase loan if it meets Regulation C's definition of home purchase.

 

This can be found in - HMDA FAQ#8 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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