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#1987184 - 01/08/15 03:00 AM Assisted Living Facilities - Short Term?
JonseyG Offline
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JonseyG
Joined: May 2014
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California
We all know that temporary housing facilities are not HMDA reportable. A good guideline to follow is if the facility is the sole and only permanent residence of the aged person then you have a solid entry for your LAR. In my case, the assisted living facility rents their "condo style" rooms on a month-to-month basis which makes me automatically think - temporary housing. The appraiser stated the facility is run like a "rental community." At this moment, the loan is not on my HMDA LAR but my concern is that this may still be HMDA reportable. I rent my apartment...and it's my permanent residence so why not and ALF? Has anyone else run into month to month rentals for assisted living?

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#1987190 - 01/08/15 03:22 AM Re: Assisted Living Facilities - Short Term? JonseyG
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Is this the residents' only home for as long as they choose to live there, and is not a nursing home?

I would go with intent vs length of lease. It is possible to live somewhere for years on a month to month lease.
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#1987193 - 01/08/15 03:54 AM Re: Assisted Living Facilities - Short Term? JonseyG
JonseyG Offline
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JonseyG
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California
This particular facility maintains housing for people showing erly signs of dementia. I haven't reached out to the banker to confirm whether or not the renters have other perm residences. The facility has onsite housing for other family to visit. The loan originally popped up on my CRA validation but quickly determined it did not meet CRA reporting standards and moved it to HMDA.

I'm going with your suggestion of 'intent' vs. lentgth of lease...it makes sense....but we all know how some ( but not all) examiners lack common sense smile

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#1987196 - 01/08/15 04:28 AM Re: Assisted Living Facilities - Short Term? JonseyG
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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I would get more info on the property and home situation of the residents. With the residents being those with early dementia, it sounds like more of a skilled care facility and I would likely be inclined to not report it for HMDA. if the residents were simply retired people renting apartments in an assisted living facility (common recreational facilities, opportunities for shared meals but also their own cooking available), that would be a different kettle of fish.
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Kathleen O. Blanchard, CRCM "Kaybee"
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The HMDA Academy
www.kaybeescomplianceinsights.com

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#1987271 - 01/08/15 03:44 PM Re: Assisted Living Facilities - Short Term? JonseyG
Dan Persfull Online
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Dan Persfull
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Bloomington, IN
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The opinions expressed are mine and they are not to be taken as legal advice.

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#1987285 - 01/08/15 03:55 PM Re: Assisted Living Facilities - Short Term? JonseyG
Truffle Royale Offline

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Please forgive a short rant.

Having worked in a nursing home/assisted living facility, I've got to say that I think the government is off their nut on this one. Nursing homes are unfortunately not a temporary living situation. The vast majority of people come into an assisted living part and then move into the nursing home as their health deteriorates. They have no permanent home elsewhere in either case. Nurses and other support is available in both situations. To say one is and one is not HMDA reportable has always struck me as just plain stupid.

Now, if you're talking about a Rehab Facility, then I see not reporting....

We now return you to using Dan's cites for guidance on how to actually report this.

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#1987312 - 01/08/15 04:25 PM Re: Assisted Living Facilities - Short Term? JonseyG
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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The thinking is that nursing facilities are more like a hospital, vs a "home" where you live your life and go about your business as much as you are able. This was not as big an issue until the proliferation of assisted living, where you could be perfectly fine and decide to move somewhere that made your life easier...more of a retirement decision vs a medical needs decision.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#1987327 - 01/08/15 04:48 PM Re: Assisted Living Facilities - Short Term? JonseyG
Truffle Royale Offline

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And that's the rub, Kathleen.

A nursing HOME has a nurse, no doctors, no operating rooms, etc., so there's no comparison to a hospital. The only difference from living at home is that there are qualified personnel who dispense meds and provide prescribed cares vs your spouse or kids doing it for you at home. It is 'where you live your life and go about your business as much as you are able.' The point being, that's as much as people are able.

I do what I'm told as far as reporting. My rant is that this is one where the government fubared. You'll not convince me otherwise so I'll just go back to pivoting my LAR now. smile

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#1987335 - 01/08/15 04:53 PM Re: Assisted Living Facilities - Short Term? JonseyG
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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Well, see, that is not 100% accurate. Many nursing homes handle very sick people who are bedridden.

The medical care by anyone is the difference and really makes no difference to me personally!

The properties reported offer no medical assistance at all. It is a clear distinction.
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Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2075790 - 04/26/16 08:01 PM Re: Assisted Living Facilities - Short Term? JonseyG
George Offline
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To rehash: an independent living community would be reported? And reported as multi-family dwelling?

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