An application was submitted with a purpose of refinancing a mixed use property. Notes provided by the branch officer, however, indicated that improvements were being made to both the mixed-use property and another residence. The mixed-use property was primarily commercial, so, under normal circumstances the loan would not be HMDA reportable. With the knowledge of the second dwelling and the proposed home improvements, would this loan be HMDA reportable? If so, would we report the dwelling as the subject property (MSA, State...) on the LAR?
Thank you!