Monthly Archive:: March 2019

Question: We have a commercial customer with a line of credit that they use for working capital. They may also use the line for any other type of business-related expense. So, the commercial borrower used this original line to purchase a rental property. Now, ...Read More

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 ...Read More

March 5, 2019 — The first day of the 2019 Regular Session of the Alabama Legislature began at noon today.  But unlike in most years, the big question in Montgomery is when the session’s second day will start. While nothing will become official, if ...Read More

Question: For HMDA purposes, would a construction-to-permanent loan be considered a refinance under the Loan Purpose? Answer: It would actually be considered a home purchase loan under HMDA regardless of whether it is a combined construction to permanent loan or the permanent financing that ...Read More