HMDA compliance can be a challenge. It takes a lot of time and training to ensure your data is accurate. While reporting the “occupancy” might seem pretty straightforward, the requirements for this field changed ever so slightly with the 2018 HMDA changes. And, as we see in our reviews, some habits can be hard to break.
David explains more in the video.
Video Transcript:
We go over to the occupancy. Pick up your pens and write this down. This is not owner occupancy; it's applicant occupancy. There's a difference. If I pledge my house for my kids to move out of the basement, my house is not theirs. They are going to buy their own place and were just using my house as collateral. Then the owner occupancy- no, the borrower occupancy. So my son and his wife are the borrowers. What's their occupancy of my place? They don't want them back, so it's not their primary residence. I don't want them back; it's not their secondary residence. Code three, you go, well, that says investment property. That's another as well. So if you have a non-borrower pledge or a third-party pledge, then you need to go with code three. So again, think about this as borrower or applicant occupancy. That's what the heading is. It's not owner occupancy.
Published
2022/11/17
