I was looking at a new manual recently purchased from a vendor regarding HMDA and was surprised to read the following:

For a home improvement loan or refinance of a home improvement loan, report the property being improved.

For a refi it was my understanding that the address reported is the property securing the loan. Has anyone else heard of reporting the improved property when it is a refi of a home improvement?

Unless there is new money for MORE improvements on the refinance of the home improvement loan, i think your manual is mistaken as the GIR indicates that for refinancings, the property being taken as security is reported.

Oops....maybe it doesn't say that. Let me go investigate.....

1.
Property location—multiple properties (home improvement/refinance of home improvement). For a home improvement loan, an institution reports the property being improved. If more than one property is being improved, the institution reports the location of one of the properties or reports the loan using multiple entries on its HMDA/LAR (with unique identifiers) and allocating the loan amount among the properties.

This from the GIR would actually seem to support what your manual says (this isn't usually an issue for me as 80% of the loans on my LAR get no geocoding and the 20% that do are very rarely HI loans).

Thanks for your comments - it was news to me!