As I understand reporting requirements, when our collateral has mixed use, residential & commercial, we are allowed to use reasonable standards to determine primary use of the property. If we determine that primary use is commercial, reporting is not necessary. Is this not correct?
OK, this is what is drving me crazy -- a refi. If you have a commercial loan secured by multiple properties, say a warehouse (value 750k) & a residential dwelling (value 150k) & if a DOT on the dwelling is retired with the loan proceeds, regrdless of the $ amount and probably done to better your lein position, you have a HMDA reportable refi.
How could they have gotten it so right on a single property that has a mixed use but so wrong when a refi is in the mix?
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