HMDA Loan Amount for Changed Terms

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    A question we received via email:
    I was putting in the loan amount for a HMDA reportable loan, but the loan officer has told me that a change in terms is going to be changing the loan amount. I was wondering which amount I am suppose to report; the amount the loan was closed with or the new amount?

    Answer: If you can provide any more details of the transaction and change in terms that would be helpful. Generally, Reg C, 1003.4(a)(7) says: For a closed-end mortgage loan, other than a purchased loan, an assumption, or a reverse mortgage, a financial institution reports the amount to be repaid as disclosed on the legal obligation.

    If it’s a counter offer, comment 1003.4(a)(7)-1 states, if an applicant accepts a counteroffer for an amount different from the amount for which the applicant applied, the financial institution reports the covered loan amount granted. If an applicant does not accept a counteroffer or fails to respond, the institution reports the amount initially requested.

    The chart on page 72 of the HMDA guide is a good reference tool for which loan amount to report.

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