– If Citizens Bank is holding the Trust (on residential real estate property) and the client request a loan using the property would this be HMDA reportable? HMDA Getting it Right (C5) states “Loans originated or purchased by the financial institution acting in a fiduciary capacity (such as trustee) is not reportable.

Alos if our client is refinancing their home which is in a trust (not with our bank), would then this application be HMDA reportable?

Can anyone provide me with Trust guidelines for HMDA (for Consumer & Commercial side)or material I can find?

Thank you

Is the bank the trustee or just the institution where the trust is maintained? If a trustee, no. If not a trustee, yes.

Loans to trust accounts that meet the definition of a home purchase, home improvement or refinancing are subject to reporting.