Should MECAs (Modification, Extension and Consolidation Agreements) be reported under HMDA as refinancings?

Compliance > Regulation C - HMDA > FFIEC FAQs
Q:  Should MECAs (Modification, Extension and Consolidation Agreements) be reported under HMDA as refinancings?
 
A:  No. The rule is unchanged: MECAs are not reportable as refinancings under Regulation C. See 67 Fed. Reg. 7221, 7227 (Feb. 15, 2002). The applicable comment was inadvertently omitted when the Commentary was revised in 2002; the comment will be restored when the Commentary is next revised.
 

This can be found in FFIEC’s FAQs on HMDA-related questions, which can be found at:  http://www.ffiec.gov/hmda/faq.htm

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