Mortgage Disclosure Act And Multifamily Lending: Part 2
Law360, New York (April 11, 2016, 11:17 AM EDT) -- Melanie Brody
Christopher E. Shelton
Elyse M. Schoenfeld
Part one of this series offered an overview of how the amended Regulation C will impact multifamily housing under the Home Mortgage Disclosure Act, including which institutions and transactions are covered. Below we address reporting issues and challenges specific to multifamily housing.
Applications and Multifamily Lending
HMDA's requirements are triggered when a financial institution receives an "application" for a covered loan. Current Regulation C defines the term "application" as "an oral or written request for a home purchase loan, a home improvement loan or a refinancing that is made in accordance with procedures...
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