I've submitted this to the HMDA help line, but haven't heard back yet. What do you think?

1) HMDA reportable? and if it is 2) What purpose?

The loan application is for a home equity loan. The stated purpose is purchase, but it's not really a purchase. A school has purchased the land on which the house is currently located. The house is being given to our applicant, but our applicant must move the house at his own expense. This loan is paying for the moving of that house to land owned by our applicant.

I would say:

1) no
and
2) to move a free house


ETA: it will be interesting to see what others (and HMDAhelp) think.

I would most likely consider this to be a renovation of the home therefore a home improvement loan. My 2¢.

We've had similar loans in the past and I've always reported as home improvement.

Purely for the sake of discussion: how is paying a moving company to load up the house and drive it down the road "improvement?" I'm having a hard time seeing the difference between this and a loan to relocate a MH. If there were set-up costs involved (foundation, well, etc) I could see a case - but just to pay the mover?

I would assume the home is being moved to a new foundation, utility hook-ups, etc. which would be improvements to the home. Otherwise are they going to just sit the house on the ground when they get it to the new location?

I guess I would want more info on the loan's purpose. It is *just* to pay the mover, or is it for the complete costs of breakdown, moving, and setting up the home at the new location?

Both times I asked the loan officer, he stated that the proceeds were being used to just move the house.

I didn't get much more direction from the HMDA Help Line: "Based on the information provided, you are suggesting the purpose of the loan is to move the existing house. Please use the exact purpose of the loan on the loan application to determine whether a loan should be HMDA reportable or not. If the loan purpose does not fit one of the three types of transactions that are HMDA reportable, then it is not HMDA reportable." Then he/she proceeded to quote the types of transactions reportable from page 8 of the GIR Guide.

If you can document that none of the improvements needed on the property to place the home on is being paid from the loan proceeds then I would most likely concede the loan is not reportable, but if any of the proceeds are being used for the permanent set up of the home on the new foundation, etc then I will probably stick with my original opinion. Again setting the home up on a new "permanent" foundation would IMO be an improvement/renovation to the home.

I was finally able to get the loan officer to get specifics - funds are going for moving AND set up (one company gets paid to do both), so we are going to report it as HIMP. I'll admit, in my mind, HIMP is still a stretch as I'm seeing it as home relocation and having difficulty saying that this is HIMP - except that you could say that adding the home to the real property improves it.

I can't seem to get the HMDA help line to just say yes or no. Once I had this additional info, I responded back to them with it, and here's the response I received today: "A home improvement loan is (a) any dwelling-secured loan to be used, at least in part, for repairing, rehabilitating, remodeling, or improving a dwelling (or the real property on which the dwelling is located) or (b) any loan not secured by a lien on a dwelling to be used, at least in part, for one or more of those purposes that is classified as a home improvement loan
by the institution. If the results of the construction do not result in improving the dwelling or the real property, then the loan would not be defined as a home improvement loan."

Well, the real property will be improved with a dwelling added to it.

HMDA requires extensive study in Philosophy.

That's why many of us don't even bother with HMDA helpline. All they do is quote chapter and verse to you. They will NEVER go out on a limb and say 'do it this way'. Normally I go over GIR until I find something that seems to fit. Then I document the living daylights out of the file as to why I did what I did. Then you have to close the file and move on or you'll drive yourself bonkers!

You're right about that. I emailed HMDA Help(less) last week with a question and 3 specific scenarios. I quoted the GIR and asked them for clarification. They replied today by quoting the exact same section of GIR that I quoted to them, no specific answers on the 3 scenarios and nothing of value. Grrr!

Same kinds of answers here. I can read, I don't need them to quote the GIR.

<<< Have had the same disappointing experience with HMDA Help. I just keep GIR handy and use these boards for help if I need it.