In regards to how to report a loan with multiple properties taken as collateral, we want to make sure we are interpreting it correctly. Our situation:

A customer is using multiple investment properties as collateral to purchase a new home. We are NOT taking the new home as collateral in any way.

Therefore, we have the option to report either one of the investment properties being used as collateral, and we do NOT report the property being purchased, correct? Also, we would then report the occupancy based on the property being reported (in this case non-owner occupied) and not the occupancy of the property being purchased, correct?

You are correct on all counts.

Just for my information....on this one what was the purpose you reported on this one? 1-Home Purchase?

Ctm1991. The loan is secured by a dwelling(s) and is to purchase a dwelling. To be compliant with Reg. C it would have to be reported as a purchase. See 1003.2.

Home purchase loan means a loan secured by and made for the purpose of purchasing a dwelling.

Cat, just to confirm, we did report this as a purchase.