I have a commercial installment loan in the amount of 413,000 where 50,000 will be used for improvements, it is secured by a 19 unit apartment complex, will be rented to college students in a low income high minority MSA. We fall into the large bank category. How should we report this loan small business or HMDA? I want to get as much credit as possible, would love to get Community Development credit but think that is out of the question. Any comments or feedback is appreciated!

Multifamily properties that are HMDA reportable can be reported both as HMDA and as community development. If the building is being improved and it will improve the neighborhood it could qualify as revitalization. If it is affordable housing, then it would qualify under affordable housing.

You do not get a choice, as a large bank, to decide to report a loan subject to HMDA as small business. In fact, because of the residential real estate it cannot be small business Type 1.

If a refinance, it can be small business Type 3 - there is a carve out for dual reporting of HMDA and small business on refinances.