Here's a good one. Commercial short term loan to a "Religious Non-Profit" organization to purchase a HUD home (1-4 single family residence) to be rehabbed and sold to "generate income". This is straight from the Loan Approval. My question (I have MANY in this case,but will stick to only one) is this loan subject to HMDA?????

Section 203.4of Reg. C describes the exempt transactions. 203.4(d)(3) says that "A financial institituion shall not report - temporary financing..."

As long as the purpose of the loan is home purchase and secured by the dwelling , it would be HMDA reportable. You just could not report this commercial loan under CRA - because the loan is made to not- for profit organization and secured by residential real estate. ( Keeping in mind we can report loans to not-for profit org. only if they are secured by nonresidential properties.

oh that's right. temporary financings are exempt!

I believe that this is not HMDA reportable because of the temporary exemption. You indicated they plan to fix up and resale this home. This gets you out of reporting.