We originated a loan to a borrower where the proceeds were to be used to payoff mortgage debt and closing costs. The loan is secured by several residential properties, 2 of which are multifamily apartment buildings. Two questions: 1. Can we report this loan as multifamily and choose one of the multifamily dwellings as the property? 2) If so, is it ok to report the full loan amount even though just 2 of the properties make this HMDA qualifying?

Please, any thoughts are appreciated! Thank you!

If the house for which you paid the mortgage off secures the loan, then I would report that property as far as the Census tract information. If it is not taken as security, our bank typically takes the one with the most value since it would represent the highest collateral value-Reg C does not give guidance on how to choose amongst the multiple properties. If you want to list more than one property on your LAR then you would use multiple entries and allocating the loan amount amongst the properties.

I would probably follow Tom's train of thought for which property to report especially if the purpose was to refinance a 1-4 dwelling and the multi-families were taken as additional collateral. Not knowing what type of "mortgage" debt was paid off puts us at a disadvantage. But, as he points out, when multiple properties are involved you can report one or all.