We have a loan that is secured by a COD and the purpose of the loan was to purchase a townhouse. My guts say no to HMDA because it is not secured by the dwelling that is being purchased. Am I correct?

Thanks!

I honestly don't know what COD stands for in this context (certificate OF deposit???).....but if it isn't secured by a dwelling and it's a purchase, it can't be reportable for HMDA.

Your gut is correct - the loan isn't secured by a dwelling (doesn't have to be the one being purchased).

Just for the record, since you referenced being "secured by the dwelling that is being purchased".....the only requirement is that a dwelling (any dwelling) secures a purchase loan for it to be reportable. It doesn't have to be the dwelling being purchased.

I like to say it this way:
There's a 2 pronged test:
1) Collateral - dwelling secured, and
2) Purpose - Purchase a dwelling.

If you can check "yes" to both, it's HMDA reportable (there are some exemptions).