Loan Amount for LAR reporting
I do not find a clear definition in the The Getting it Right Guide for what to report as "loan amount". There are several terms and definitions of the loan amount. HOEPA uses the "Total Loan Amount" for high cost calculations--which is Amount Financed less any points and fees not included in the finance charges. Anyone had this come up? MorVision (through Dynatek) auto transfers and reports a calc of the loan amount plus any one time PMI payments as the LAR figure, of course rounded to thousands).
Here is what the 2004 Staff Commentary has to say about Loan Amount. If you need a copy, please request a copy from Angela. You can also find the Staff Commentary on the FFIEC.GOV site in PDF format. Hope this information helps. 7. Loan Amount. Enter the amount of the loan or application. Do not report loans below $500. Show the amount in thousands, rounding to the nearest thousand (round $500 up to the next $1,000). For example, a loan for $167,300 should be entered as 167 and one for $15,500 as 16. a. For a home purchase loan that you originated, enter the principal amount of the loan. b. For a home purchase loan that you purchased, enter the unpaid principal balance of the loan at the time of purchase. c. For a home improvement loan, enter the entire amount of the loan—including unpaid finance charges if that is how such loans are recorded on your books— even if only a part of the proceeds is intended for home improvement. d. If you opt to report home-equity lines of credit, report only the portion of the line intended for home improvement or home purchase. e. For refinancings, indicate the total amount of the refinancing, including both the amount outstanding on the original loan and any amount of “new money.” f. For a loan application that was denied or withdrawn, enter the amount applied for.