Skip to content
BOL Conferences
Thread Options
#1959643 - 09/05/14 02:47 PM Business loan to purchase condo
Heather301, CRCM Offline
100 Club
Joined: Nov 2006
Posts: 105
The LLC has purchased a condo (1-4 family) for employees to use when they are in town. They do not reside there permanently. Is this HMDA reportable?
_________________________
Live simply, Love generously, Care deeply, Speak kindly, Leave the rest to God.....

Return to Top
HMDA

   
HMDA Academy
#1959646 - 09/05/14 02:50 PM Re: Business loan to purchase condo Heather301, CRCM
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
I would not report this as the use is transient housing, in lieu of putting employees up in hotels.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#1959777 - 09/05/14 06:34 PM Re: Business loan to purchase condo Kathleen O. Blanchard
Heather301, CRCM Offline
100 Club
Joined: Nov 2006
Posts: 105
Kathleen thanks for your prompt response. Is there a specific area of the regulation that speaks about transient housing? I would like to have something to base my decision on to show examiners.

Thanks!
_________________________
Live simply, Love generously, Care deeply, Speak kindly, Leave the rest to God.....

Return to Top
#1959785 - 09/05/14 06:47 PM Re: Business loan to purchase condo Heather301, CRCM
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 9,111
OK
Not Kathleen, but check out Reg. C's commentary to 1003.2 if you're looking for a citation. Specifically, it reads:

2. Exclusions. Recreational vehicles such as boats or campers are not dwellings for purposes of HMDA. Also excluded are transitory residences such as hotels, hospitals, and college dormitories, whose occupants have principal residences elsewhere.

Last edited by raitchjay; 09/05/14 06:48 PM.
_________________________
I'm fixin' to fix that.

Return to Top
#1959793 - 09/05/14 06:53 PM Re: Business loan to purchase condo Heather301, CRCM
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 9,111
OK
For your scenario, the key phrase is "...whose occupants have principal residences elsewhere" (in case your examiners try to say, 'but this is a condominium, not a hotel').
_________________________
I'm fixin' to fix that.

Return to Top

Moderator:  SMQ, CRCM