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#2162903 - 02/02/18 03:38 PM Refi or HI
Cat Lover Offline
100 Club
Joined: Jun 2016
Posts: 147
Working with scrub 2017 HMDA. Made a loan to refinance property but a portion of the funds were going to be use for improvement, does it matter if the refinancing $ portion is greater than the portion for home improvement? Report purpose 3 or 2? Thanks.

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#2162909 - 02/02/18 03:46 PM Re: Refi or HI Cat Lover
#12 Offline
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Joined: Jun 2005
Posts: 1,338
2017 rules, home improvement trumps refi, so if even $1 was used for home improvement, it's reported as home improvement.
Purpose code 2.
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#2162910 - 02/02/18 03:53 PM Re: Refi or HI Cat Lover
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,643
I agree with #12 that the portion does not matter. This is a HI loan.

From the GIR:
Multiple-category loans. If a loan is a home improvement loan as well as a refinancing, an institution reports the loan as a home improvement loan.
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All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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#2162916 - 02/02/18 04:21 PM Re: Refi or HI Cat Lover
Cat Lover Offline
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Joined: Jun 2016
Posts: 147
Just wanted to make sure, thank you.

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#2163023 - 02/02/18 09:02 PM Re: Refi or HI Cat Lover
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
Majority never wins when it comes to HMDA purpose.
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#2163101 - 02/05/18 03:33 PM Re: Refi or HI Cat Lover
RR Joker Offline
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Joined: Nov 2002
Posts: 20,654
The Swamp
Well, maybe it does...for mixed use/property anyway wink
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#2163167 - 02/05/18 09:31 PM Re: Refi or HI Cat Lover
David Dickinson Offline
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David Dickinson
Joined: Nov 2000
Posts: 18,762
Central City, NE
I disagree.

Just because the majority of square feet is dwelling, doesn't mean the properties primary use is dwelling. That is one factor. If I buy a building that has non-residential space on the first floor and apartments on the 2nd and 3rd floor, the majority of space is dwelling. However, that doesn't make it a "Dwelling" for HMDA.

It could be the non-residential space provides 3/4th of the income. Ask the borrower why they bought the building and most will tell you they wanted the main street store frontage. They didn't want to be in the apartment rental business, but they aren't going to let the apartments just sit unoccupied. In this scenario (which is very common), I would never call those buildings "dwellings" for HMDA.
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