We did a consumer loan for a customer. The customer secured the loan with a CD for the full amount of the loan. As an abundance of caution the bank also used the customers primary residence as collateral. I am being told that this is not HMDA reportable. I'm not sure that is true. We are holding the dwelling as collateral, so my thought is we would report. I would appreciate anyone's opinion. Thanks!

What was the purpose of the original loan. That is your determining factor. If it wasn't to purchase, improve or refinance residential real estate then the loan is not HMDA reportable.

Just because you have a home as collateral does not automatically make the loan HMDA reportable.

The loan was used to pay off two mortgages one on the primary and one on an investment. We decided to report the loan due to purpose. Thanks for the help.

From your second post I would agree with you.