Question:
We have a question on a loan that is a refinance of a purchase of a second home and is adding funds to pay off personal credit cards. Should be report the HOEPA Status as "Code 3 - NA"? Answer: Assuming the loan is just secured by the second home and is not also secured by the principal dwelling, then yes, it should be reported as "Code 3 - NA" like you said. The reason for this is that HOEPA only applies to: ...a high-cost mortgage, which is any consumer credit transaction that is secured by the consumer's principal dwelling... https://www.consumerfinance.gov/policy-compliance/rulemaking/regulations/1026/32/ So the HOEPA rules do not apply to this particular loan and, thus, it would be reported as not applicable for HMDA purposes. Comments are closed.
|
Archives
March 2020
CategoriesCompliance Alliance offers a comprehensive suite of compliance management solutions.
To learn how to put them to work for your bank, call (888) 353-3933 or email info@compliancealliance.com. |