If we are paying off a lien on a rental dwelling, but we are securing the new loan with a lien on their primary dwelling, do we need monitoring information? We are paying off a lien on a dwelling with a lien on the dwelling, just not the same dwelling. Please advise.
If you are a HMDA reporting bank and it is a HMDA reportable transaction then you should obtain monitoring information. If not, you are not permitted to collect it under Reg B since the application does not relate to a principal dwelling.