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#2150857 - 10/23/17 07:29 PM Mixed use test - CRA and HMDA
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Joined: Nov 2008
Posts: 1,055
In the mountains
We originated a loan for the purchase of a mobile home park with 6 manufactured homes. There are 11 pads total. 6 of these pads have manufactured homes permanently affixed are were part of the purchase. The owner rents outs these 6 manufactured homes for $350 - $550/ month. The 5 pads are rented for $150/ month.

The loan is being reported for CRA as a small business loan because it falls under 1E2 - Loans secured by other nonfarm nonresidential properties. This is because the loan was for $170,000, the land value is $160,000 and the manufactured homes are worth $80,000 total.

My first reaction is that it would be a HMDA reportable loan since there are more dwellings than pads and the income from those dwellings will be more than the income from the pads. But this would mean reporting for HMDA and CRA which is typically not done.

So can it be excluded from HMDA reporting by applying the same test - the mobile home value is less than 50% of the loan principal amount - as the mixed-use test?
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#2150885 - 10/23/17 09:11 PM Re: Mixed use test - CRA and HMDA Likes to Comply
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Diamond Poster
Joined: Nov 2008
Posts: 1,055
In the mountains
Are we classifying this incorrectly for call report? Should it really be "All other loans secured by first liens on 1-4 family residential properties regardless of purpose?
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#2150932 - 10/24/17 01:59 PM Re: Mixed use test - CRA and HMDA Likes to Comply
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,762
Bloomington, IN
Search the following document using "double counting" or "double reporting" as the search term.

http://www.fdic.gov/news/news/financial/2005/fil2905a.html
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#2151020 - 10/24/17 07:48 PM Re: Mixed use test - CRA and HMDA Likes to Comply
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In the mountains
Thanks for the info.
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