When doing a commercial loan for a customer to pay off an unsecured personal note and also do renovations on a rental property, would this be HMDA reportable? A majority of the funds are being used to pay off the existing loan (not reportable), but renovations is also included in the funds.

From HMDA: Getting It Right 2013:

Home improvement loan.
A home improvement loan is: (a) any dwelling-secured loan to be used, at least in part, for repairing, rehabilitating, remodeling, or improving a dwelling or the real property on which the dwelling is located; and (b) any loan not secured by a lien on a dwelling—that is: (i) to be used, at least in part, for one or more of those purposes, and (ii) is classified as a home improvement loan by the institution.

There used to be a "50% rule", but that went away some time ago.

So the answer is, Yes, it is HMDA reportable IF your institution codes or identifies non-dwelling secured home improvement loans in any way.

Hope this helps.

If the new loan is secured by a dwelling, there is no classification requirement. All dwelling-secured loans with any proceeds used for improvements are reportable.

HMDA never considers the majority of funds (same with the new proposal). If ANY amount is to purchase, improve or refinance, it is reported.

Thank you all so much for your input. This has helped greatly.