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#2117535 - 02/08/17 07:50 PM 1-4 and multifamily on same loan
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
I have a loan to refinance an apartment complex. There are 2 buildings. Building 1 has 4 units. Building 2 has 12 units. How should we code this? I can’t find anything in current HMDA that talks about a “pecking order” among dwelling type reporting.
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#2117613 - 02/09/17 01:31 PM Re: 1-4 and multifamily on same loan Dani York, CRCM
Adam F Offline
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Adam F
Joined: Apr 2013
Posts: 420
VA
I was not able to find anything provided in the regulation or GIR that tells you how to proceed either.

So in the past we have always reported it as multi-family since we don't have a lot of those for our LAR.
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#2117636 - 02/09/17 03:42 PM Re: 1-4 and multifamily on same loan Dani York, CRCM
Dani York, CRCM Offline
Power Poster
Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
Thank you!
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I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.

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#2117969 - 02/13/17 04:32 PM Re: 1-4 and multifamily on same loan Dani York, CRCM
JoAnne Offline
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Joined: Feb 2001
Posts: 795
Michigan
I have a similar situation. Loan is to an individual. Property consists of the "Main"' building which is a duplex and an 11 unit apartment complex. (Appraisal clearly shows the duplex separate from the apartments on the same property). If I put this on the LAR as Multi-Family, I get a validity error that says Property Type=3; therefore income must = NA. The borrower is living in the main building (duplex). Loan is to refinance duplex and apartments).

How should I report this since there was income relied on in the credit decision.
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#2117974 - 02/13/17 04:47 PM Re: 1-4 and multifamily on same loan Dani York, CRCM
burke116 Offline
Platinum Poster
Joined: Jun 2014
Posts: 566
Petersburg, VA
Check out page 16 of the Getting it Right guide:

Income of the applicant. If an application relates to a one- to-four- family dwelling, enter the total gross annual income your institution relied on in making the credit decision. For example, if your institution relied on an applicant’s salary to compute a debt-to-income ratio, and also relied on the applicant’s annual bonus to evaluate creditworthiness, report the salary and the bonus. Report the amount in thousands, rounded to the nearest thousand ($500 should be rounded up to the next thousand).
Enter “NA” if
—your institution does not take the applicant’s income into account,
—the loan or application is for a multifamily dwelling,
—the transaction is a loan purchase and you choose not to collect the information,
—the transaction is a loan to, or application from, an employee of your institution and you seek to protect the employee’s privacy, even though you relied on his or her income, or
—the borrower or applicant is a corporation, partnership, or other entity that is not a natural person.

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