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.

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.

Yes, it is an improvement, unless of course you also financed the purchase.

Thank you both.

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?

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.

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?

Yes, it sure is!