FORUM PROFILE

Re: HMDA Temporary Financing

Home Forums Home Mortgage Disclosure Act HMDA Temporary Financing Re: HMDA Temporary Financing

#2912
dmurray
Participant

This sounds like a HELOC to me. I’d first find out if that’s something your institution reports. We don’t, therefore this wouldn’t be a reportable loan. We don’t even offer these types of products.

I researched a little bit on BOL (shhh, don’t tell anyone) and here is a link with an answer. HMDA’s GIR really didn’t specifically say anything about the definition of what temp financing is.

https://www.bankersonline.com/compliance/guru2008/gurus_comp022508c.html

Also you had asked about reporting each succeeding refinance? Yes. I would, but I’d check to see if this would be a modification/extension first because that can get a little iffy as to reportability.