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#2047526 - 11/02/15 06:05 PM Converting Commercial Building to Apartments
Live&Learn Offline
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Would converting a commercial building to apartments be HMDA reportable. It will be secured by the same commercial building.
Seems like home improvement but I'm not sure.
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#2047529 - 11/02/15 06:18 PM Re: Converting Commercial Building to Apartments Live&Learn
TMatt87 Online
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I've had a similar loan and I reported it as home improvement. I believe I asked a similar question on here and received mixed answers. So I erred on the side of caution and reported it. This was a few years ago and I don't think it was selected in our last HMDA audit.
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#2047531 - 11/02/15 06:22 PM Re: Converting Commercial Building to Apartments Live&Learn
Kathleen O. Blanchard Offline

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Yes, it is an improvement, unless of course you also financed the purchase.
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#2047603 - 11/02/15 08:32 PM Re: Converting Commercial Building to Apartments Live&Learn
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Thank you both.
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#2048017 - 11/04/15 05:48 PM Re: Converting Commercial Building to Apartments Live&Learn
Colorado Girl Offline
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What if the applicant already owns the commercial building, then takes out a loan to convert the commercial offices to a four-plex (with another institution). We are now terming the renovation loan to permanent financing. I don't believe it's purchase, because the structure was already owned. It's not HI because no new monies were for improving. Would it be considered a HMDA refi because the original note was dwelling-secured at the end of the note? Or is it not reportable because the original note was originally secured by the commercial offices?

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#2048021 - 11/04/15 05:54 PM Re: Converting Commercial Building to Apartments Live&Learn
Colorado Girl Offline
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I suppose if the renovation loan is considered HI because it converts the structure to dwellings (as outlined above), then the refinance of that loan should be considered a refinance.

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#2048022 - 11/04/15 05:54 PM Re: Converting Commercial Building to Apartments Live&Learn
Kathleen O. Blanchard Offline

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Well, the original note was secured by an office building that was converted to residential, so you are paying off a residential secured loan, correct?
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Kathleen O. Blanchard, CRCM "Kaybee"
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The HMDA Academy
www.kaybeescomplianceinsights.com

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#2048029 - 11/04/15 06:01 PM Re: Converting Commercial Building to Apartments Live&Learn
Colorado Girl Offline
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Yes, it sure is!

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