I am having a brain lapse. If we do a loan with an individual but a separate entity owns the real estate (such as a real estate holding co or individual trust) we report based on the individual correct?

You report on the loan applicant, not on who owns the property. But in this case, what type of loan would be HMDA reportable?

It is a loan to the individual who has an LLC which is a real estate holding entity. THe LLC pledged the home as collateral. It is a refinance of an existing note secured by a 1-4 family dwelling that will be secured by the same dwelling.

OK - just was trying to figure out whether or not this was even reportable.

I definitely appreciate that. Thank you for the help!

we report based on the individual correct

That depends on what information you are referring to. If you are referring to occupancy then you report the occupancy status based on if the owner of the property occupies it as their primary residence.