We report multiple properties on multiple HMDA LAR lines. We have a loan from an individual to purchase two properties, one 1-4 family investment property and one multifamily residence.

For the LAR line with the multi-family property I report income as NA. But I am questioning the income for the 1-4 family property. Do I put actual income or NA? I haven't found any specific guidance but it just seems weird to report an income for one of them. Since the borrower is also buying a multi-family residence with the same transaction, I am leaning towards NA for the 1-4 family, since the reason that we don't report income for multi-family transactions would affect the 1-4 family purchase.

How do others see this?

When ever given an opportunity to not report, we choose that path as it reduces errors opportunities, We only report one of the properties. If income was used, then it would need to be reported.

I agree with JSD, don't report what you don't have to. But, if you choose to, then follow the reg and report the income.

Thank goodness this type of reporting will go away in 2018.

Yes, Kathleen. This will get simpler for us. (Never thought I would say that about the New HMDA Rule.)

We have reported multiple LAR lines because it provides more instances of rental properties in low and moderate income tracts.

This one was unusual because each of the 2 LAR lines would have a different income. After submitting my initial question, I thought that, if I were reporting this on one line, it would be NA for income because of the multi-family dwelling. So perhaps income for the other line should be NA because the loan does, in fact, involve a multi-family, even if not reported on that LAR line?

I would go with that..