Is this considered HMDA Purchase?

Borrower is LLC - owns 16 acres out right which is a mobile home park (land only) - is getting a loan to improve the park, by doing land development and purchasing mobile home units which will be taken along with the land as collateral. The park has 80+ unit lots.

Would this be HMDA, Purpose 1 (Home Purchase), Owner Occupancy 3 (not applicable because multi-family), property type 3 (multi-family)???

Each Mobile Home is a separate unit, but if it gets into dozens and dozens of them - that would then be multi-family?

Adding a cog into this - while the majority of the loan proceeds will go through loan development and buying the mobile home units - a portion of it will go to purchasing 4 acres which are zoned commercial (and does have commercial buildings on it) - because the original parcel was 20 acres, and the LLC is buying the 4 acres to add to the 16 they own already so that the original parcel will be complete again.

Please advise. Thank you. (Oh, and the loan is for less than $1 million.)

I would say purchase, but you have multiple 1-4 family dwellings, not a multifamily. So, I would say purchase, 1-4 family, non-owner occupied.

But I am not a guru...

I agree with #12, FWIW.

I just spoke with my former HMDA officer at another bank - she said she had to verify it with the FED, but that it was multiple 1-4 family dwellings - not multi-family because that's five or more under one roof.

FWIW - I would code as purchase, 1-4, not owner occupied also.

A multi-family building is a 5+ unit, the emphasis is on unit.
Examples-- (not to insult anyone's intelligence, but maybe to help a newbie who may be just now in the deep end of HMDA )
single family home = 1-4 unit
duplex = 1-4 unit
3 duplexes on one loan = 1-4 unit
4-plex = 1-4 unit
2 4-plexes on one loan = 1-4 unit
6 unit apt bldg = multi-family
you get the idea!!!!!


And just for fun-----------
a single condo = 1-4 unit
a condo building with 5 or more units = multi-family

mobile homes for either sale or rent = HMDA and 1-4 unit
Mobile home dealer that buys MH for resale = not HMDA, just inventory!!!!

Gotta love HMDA (translation-job security)

I disagree with this one. Condos are 1-4 family. Five or more condos would be multiple 1-4 dwellings, like the 3 duplex example above.

Since I have never had this loan and not likely to make a loan to one business or individual for a whole building of condos, I will defer to your expertise.