I have a customer that is a business and they are purchasing an investment property. This property is in the middle of town and does include an apartment bldg. of six efficiency apartments that he is planning on tearing down because they are inhabitable, and this is mentioned in the appraisal. Since the customer does plan on tearing them down would this be HMDA reportable?

Thanks.

I would say not reportable. You can rely on the borrower's stated purpose for HMDA, and since the building won't be used as a dwelling, you don't have to report.

However, make sure to run a flood determination, because you can't use stated purpose for that.

I would want to know what they are going to do with the property after the apartments are razed before opining.

Thanks. And flood has been pulled, and Dan, it is stated in the appraisal that the borrower plans on tearing them down and then marketing the land as commercial property for new commercial development.

Thank you both.

In that case I would agree the loan would not be reportable.