So it direct thing is actually one of several some thing I pointed out during my HMDA opinion letter, and you will develop they are going to address it throughout the final rule inside two months.
TMatt is right that there is no certain recommendations into the HMDA for two phase money from the other financial institutions having a hey loan, but:1) there is certainly obvious advice to own structure / long lasting loans (report as the a buy) & 2) whenever they had been one another at your bank, you might report the fresh new long lasting stage due to the fact a hi loan. (بیشتر…)