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HMDA & Multi-family Dwellings
Answer by Todd Cooper, EVP CRA Products, PCi Corporation
Question: Is a 2-story townhouse building considered 1-4 family or multifamily for the purpose of HMDA?
Answer: For 2003 data reporting, the purpose code for multi-family should only be used on loan applications for dwellings with five or more families. A loan application on a townhouse with two family units, should be reported with 1 (home purchase,) 2 (home improvement,) or 3 (refinancing) purpose code.
For 2004 data reporting, property type (one of the new 2004 variables) for multi-family should only be used on loan applications for dwellings with five or more families. A loan application on a townhouse with two family units, should be reported with a property type code of 1 (one to four-family.)
PCi Corporation is the leading provider of compliance risk management solutions that ensure financial institutions fully comply with the Community Reinvestment Act (CRA), the Home Mortgage Disclosure Act (HMDA), fair lending and anti-predatory laws, as well as the National Flood Insurance Reform Act. More than 90 of the nation's top 100 banks, numerous community banks, and many of the federal and state regulatory and enforcement agencies rely on the company's compliance products, data, and services. More information about PCi can be found at www.pciwiz.com.
First published on BankersOnline.com 8/18/03

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