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#2104433 - 10/25/16 01:32 PM commercial or Primary Residence both same address
Catm1991 Offline
100 Club
Joined: Jul 2014
Posts: 194
MO
For some reason the past week I am having trouble thinking with a couple of loans wondering if they are indeed HMDA reportable...I have a loan that is a refinance and it's a sawmill, but does have their primary residence on the property. The loan does have a Business Purpose Statement in the loan file stating it's too refinance their business, so I am wondering since the loan officer has put this in the loan and the intent and purpose of this loan is to refinance the customers business, even though a mobile home, their primary residence, is on the property if it would indeed not be HMDA reportable?

Need help please??

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#2104436 - 10/25/16 01:35 PM Re: commercial or Primary Residence both same address Catm1991
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,293
The financial institution must determine what the primary use of the property is in a mixed use situation. If the primary use of the property is the saw mill and related structures, rather than the residence, then the property is not residential for HMDA regardless of the use of proceeds.

Document the method used to make the determination.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

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#2104444 - 10/25/16 01:51 PM Re: commercial or Primary Residence both same address Catm1991
Catm1991 Offline
100 Club
Joined: Jul 2014
Posts: 194
MO
Ok, thank you so much Kathleen. I didn't report but again, I kept doubting myself, so this week I came in thinking, well maybe it should be reported! So I just needed another prospective. Thank you

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