Would this be HMFDA reportable? I have an application where the customer wants to purchase a church building and then turn it into a 8 bed residential facility. Would this be HMDA applicable?

Thanks.

You always look at what the building will be once the funds are applied. If you understand the "church" will become a residence, then it sounds like a HMDA purchase.

Likewise, if someone is buying a house and turning it into an office/business, then it's no longer a dwelling. IOW, it's not what it is. It's what it will become with your loan.

Ok, that is what I was thinking as well. Thank you David.

One step further, you'll need to determine that the 8 bed residential facility won't be transitory in nature, and thus exempt from HMDA reporting.