I am looking at a chart that indicates which property to reported on HMDA and it seems confusing. If you purchase A & B and secure it with C and D - it shows that you can report the address for A, B, C or D. I thought on Purchases & Refis it is the property taken as collateral...and on HI it is the property being improved as the address to report.
There is another section that shows a purchase of A and secured by B & C and the property to be reported is A...???

If it's a purchase or refi, you report the collateral address. If there is more than one dwelling as collateral, you can pick which property to report, with one exception - for a purchase, if one of the properties used as collateral is being purchased, you report that property.

If it's home improvement, report the property being improved. If more than one property is being improved, you get to pick which one to report.

JSD: What "chart" are you referring to? Can you give a link?

It appears to be created by a department - nothing official!

Let me ask this......when there is a purchase of a dwelling that is not the customer's dwelling, but it is secured by the customer's dwelling? I know we use the customer's dwelling as the property address, but when it comes to filling out the rest of the HMDA data, do we use that property as well to describe the property type and owner occupancy? The dwelling that the customer is purchasing is a mobile home and it's the daughter's home.

Owner Occupancy.
Indicate whether the property to which the loan or loan application relates is to be owner-occupied as a principal residence by entering the applicable Code from the following:

Property Type. Report whether the loan or application was for manufac-tured housing, a multifamily dwelling, or a one- to-four-family dwelling other than manufactured housing.

Thank you!

but when it comes to filling out the rest of the HMDA data, do we use that property as well to describe the property type and owner occupancy

When there are multiple properties involved you report the applicable information for the property being reported on the LAR. For purchases and refinances that is the property securing the loan and for home improvement loans it is the property being improved.

Well crud, so in this case, we would not report the mobile home they are purchasing for owner occupancy and property type. Instead, we would use the dwelling the loan is secured by?

That is correct.

Thanks Dan!

Sorry - let's try again.

1. Occupancy—multiple properties. If a loan relates to multiple properties, the institution reports the owner-occupancy status of the property for which property location is being reported.

Thanks rlcarey!

okay- what about a loan on non owner occupied property and proceeds will be used for home improvements to two different properties- but I don't have an address for them- so do I still report on HMDA as Home Improvement and use the address that is being used for collateral?

No. You need the loan officer to find out what properties are being improved and report based on one or both of the properties being improved.

If the loan officer did not collect the required information to accurately report the HMDA data then you have a flaw in your process and management needs to address it accordingly.

From the GIR, page 2.

Management's Responsibilities

If your institution is required to comply with HMDA, management must ensure that:

Procedures are in place for collecting and maintaining accurate data regarding each loan application, loan origination, and loan purchase— for home purchase loans, home-improvement loans, and refinancings.

okay - Thanks Dan.
We are meeting tomorrow on some other issues, so I will add that to the list.
Thanks again for the help.