{"id":2347,"date":"2021-01-29T17:21:27","date_gmt":"2021-01-29T17:21:27","guid":{"rendered":"https:\/\/albanknews.com\/?p=2347"},"modified":"2021-01-29T17:21:27","modified_gmt":"2021-01-29T17:21:27","slug":"2347","status":"publish","type":"post","link":"https:\/\/albanknews.com\/?p=2347","title":{"rendered":""},"content":{"rendered":"

Q<\/strong>: We have an applicant who is doing a cash-out refinancing. They stated they will use the funds for a purchase of another dwelling, but it is at an unknown, future date.\u00a0 Would this still make it a \u201cHome Purchase\u201d loan for HMDA purposes?<\/p>\n

A:<\/strong>Yes, you would code this as a “Home Purchase” loan. You can rely on the applicant\u2019s representation as to the use of the loan proceeds. For a multi-purpose loan, \u201chome purchase\u201d trumps \u201crefinance.\u201d<\/p>\n

Reference: A financial institution may rely on the oral or written statement of an applicant regarding the proposed use of covered loan proceeds.<\/p>\n

Comment 1 to 12 CFR \u00a7 1003.4(a)(3):https:\/\/www.consumerfinance.gov\/rules-policy\/regulations\/1003\/4\/#4-a-3-Interp-1<\/a><\/p>\n

Section 1003.4(a)(3) requires a financial institution to report the purpose of a covered loan or application. If a covered loan is a home purchase loan as well as a home improvement loan, a refinancing, or a cash-out refinancing, an institution complies with \u00a7 1003.4(a)(3) by reporting the loan as a home purchase loan.<\/p>\n

Comment 3 to 12 CFR \u00a7 1003.4(a)(3):https:\/\/www.consumerfinance.gov\/rules-policy\/regulations\/1003\/4\/#4-a-3-Interp-3<\/a><\/p>\n

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