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!

Can't help you with the CRA part as we aren't a CRA reporter, but yes, it is HMDA reportable.

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:



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

Thanks