I am scrubbing our LAR and we have a refinance which is clearly HMDA. As part of the refi, they are releasing one of the dwellings.

Loan Operations geocoded the property and recorded that dwelling for reporting purposes. Is this ok to do? I am unable to find anything about partial releases in any of the guidance except for that it is a refinance. I am thinking that since this property was released, it is no longer securing the loan and therefore the property still securing the loan should be the reported geocode information.

Does anyone have any concrete guidance on this?

Refer to the HMDA GIR Appendix D Paragraph 4(a)(9).

Here is the link to the guide.

http://www.ffiec.gov/hmda/pdf/2013guide.pdf

Appendix A to Reg C states to enter the information to indicate the location of the property to which the loan relates. If the refi no longer relates to the released property, why would that property be geocoded?

Thank you. That is exactly what I was thinking and I am happy to know now where to find the info. :-)