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#2083590 - 06/15/16 06:13 PM Commercial Loan
TTFN Offline
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Joined: May 2015
Posts: 18
Missouri
Borrower is a business. Bank uses business owners primary dwelling as collateral. We are refinancing another loan to the business that was ALSO secured by business owners primary dwelling - therefor it is HMDA reportable as a refinance. My question is this....Owner occupied? how does a business "live" in a house? or is it "Not Applicable"? Thanks for your help!

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#2083597 - 06/15/16 06:25 PM Re: Commercial Loan TTFN
raitchjay Offline
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Joined: Oct 2009
Posts: 9,086
OK
As of now, you are to report "owner" occupancy, not "borrower" occupancy. Sounds like the business owner individually owns his home and has pledged it as collateral for the loan to the business. The fact that your borrower is the business doesn't change the fact that the OWNER of the home does occupy it as his primary residence; so you'd report it as owner-occupied.
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#2083600 - 06/15/16 06:27 PM Re: Commercial Loan TTFN
TTFN Offline
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Joined: May 2015
Posts: 18
Missouri
Makes perfect sense - thank you so much!!

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#2083607 - 06/15/16 06:43 PM Re: Commercial Loan TTFN
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
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And I agree with. RJ. For now, it is owner occupied. That will change in 2018.
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#2083932 - 06/17/16 02:15 PM Re: Commercial Loan TTFN
SMQ, CRCM Offline
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Between the lines
That was a great explanation RJ, I have seen this explained many times, but yours was one of the best written that I have seen.
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#2083935 - 06/17/16 02:20 PM Re: Commercial Loan TTFN
raitchjay Offline
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Posts: 9,086
OK
Thanks SMQ.
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