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#1643671 - 12/28/11 03:39 PM Which property to use
Glo Offline
Gold Star
Joined: Jul 2005
Posts: 394
Arkansas
I am looking at a loan that is to purchase a rent house, but the loan is secured by their primary dwelling. I need to find out which property we are to put on the HMDA sheet. I want to say the primary dwelling, since it is the collateral, but then I start to wonder about owner occupancy, and wonder if I should put the rent house. Can anyone lead me in the right direction, please?

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#1643674 - 12/28/11 03:31 PM Re: Which property to use Glo
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
From the HMDA Getting It Right Guide (under property location):

4(a)(9) Property location.

1. Property location—multiple
properties (home improvement/
refinance of home improvement).

For a home improvement loan, an
institution reports the property being
improved. If more than one property is
being improved, the institution reports
the location of one of the properties or
reports the loan using multiple entries
on its HMDA/LAR (with unique identi-
fiers) and allocating the loan amount
among the properties.

2. Property location—multiple properties
(home purchase/refinance
of home purchase). For a home
purchase loan, an institution reports
the property taken as security. If an
institution takes more than one property
as security, the institution reports
the location of the property being purchased
if there is just one. If the loan
is to purchase multiple properties and
is secured by multiple properties, the
institution reports the location of one
of the properties or reports the loan
using multiple entries on its HMDA/
LAR (with unique identifiers) and allocating
the loan amount among the
properties.

3. Property location—loans purchased
from another institution.
The requirement to report the property
location by census tract in a metropolitan
area where the institution has
a home or branch office applies not
only to loan applications and originations
but also to loans purchased
from another institution. This includes
loans purchased from an institution
that did not have a home or branch
office in that metropolitan area and
did not collect the property-location
information.

4. Property location—mobile or
manufactured home. If information
about the potential site of a mobile or
manufactured home is not available,
an institution reports using the code
for “not applicable.”
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1643677 - 12/28/11 03:34 PM Re: Which property to use Glo
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
Also from GIR

Occupancy—multiple properties.

If a loan relates to multiple properties,
the institution reports the owneroccupancy
status of the property
for which property location is being
reported. (See the comments to paragraph
4(a)(9), Property location.)
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1643679 - 12/28/11 03:48 PM Re: Which property to use Glo
Glo Offline
Gold Star
Joined: Jul 2005
Posts: 394
Arkansas
Thanks for your help! smile

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#1644051 - 12/29/11 04:43 AM Re: Which property to use Glo
Denovo Co Offline
Gold Star
Joined: Jan 2005
Posts: 375
NM
We have a similar situation. A loan that is for the purchase of an investment property but is secured by the borrower's other investment properties. The borrower had different loans secured by mulitple properties at several institutions and we paid them all off with our one loan and gave additional funds to purchase another property. We did not take the purchased property as collateral. I believe that this is a purchase , but don't know what property to report. ??

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#1644053 - 12/29/11 09:30 AM Re: Which property to use Glo
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
See point 2 above for your answer. Select one of the properties used as collateral or divide the loan and use all collateral. Easier to just pick one.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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