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#1886246 - 01/14/14 02:28 PM Motel with Residence - Refinanced
Likes to Comply Offline
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Joined: Nov 2008
Posts: 1,061
In the mountains
We have a commercial loan that is secured by a motel and an onsite single-family residence that is used by the person running the hotel. It is being refinanced and was previously secured by the same collateral. I just want to confirm that this is HMDA reportable since there is a single-family residence included as collateral; and that it is CRA reportable as well since it is a "loan secured by other nonfarm nonresidential properties" due to the motel?

Thanks in advance for your help!
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#1886247 - 01/14/14 02:30 PM Re: Motel with Residence - Refinanced Likes to Comply
raitchjay Online
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Joined: Oct 2009
Posts: 8,830
OK
Can't help you with the CRA part as we aren't a CRA reporter, but yes, it is HMDA reportable.
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#1886746 - 01/15/14 12:30 PM Re: Motel with Residence - Refinanced Likes to Comply
learningdaily Offline
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Joined: Dec 2013
Posts: 33
Since my time in a compliance/review capacity (only about 2 yrs) I was under the impression that you can't double count a loan as CRA and HMDA. HMDA trumps CRA. This has also been the thought of many of my co-workers with a wider breadth of experience. I'm stating this only because you may likely have someone tell you that you can't doubloe count as that seems to be a common thought. This being said, there was a recent post in the CRA forum where this very issue was commented on by Kathleen B. See below:

Originally Posted By: Kathleen B
Re the original question, if the loan is not HMDA reportable, the loan will be CRA reportable as a small business loan if the primary collateral is the non-residential property.

Re refinances, there is an exception and loans that are HMDA reportable as a refi can also be a CRA small business loan. If there are a large number of them examiners may adjust the numbers manually to avoid skewing performance but otherwise the loan can be in both category.



http://www.bankersonline.com/forum/ubbthreads.php?ubb=showflat&Number=1878683#Post1878683

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#1886776 - 01/15/14 01:54 PM Re: Motel with Residence - Refinanced Likes to Comply
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In the mountains
Thanks smile
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