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#2161578 - 01/23/18 09:08 PM Total Individual Units&Multifamily Affordable Uni
TeamComply Offline
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These data reporting fields pertain to all property types, correct? Not just manufactured homes? We are questioning this since it falls below the manufactured home secured property type and interest data fields. This may be a dumb question, I just want to be sure we understand these fields correctly. Thanks.
Last edited by TeamComply; 01/23/18 10:12 PM.
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#2161630 - 01/24/18 02:36 PM Re: Total Individual Units&Multifamily Affordable Uni TeamComply
Compliance NABW Offline
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The multifamily affordable units field is only for multifamily dwellings, which can include manufactured home communities, but would also include apartment buildings, condominium complexes, and cooperative buildings or complexes.

See 12 CFR 1003.4(a)(32) - If the property securing the covered loan or, in the case of an application, proposed to secure the covered loan includes a *multifamily dwelling*, the number of individual dwelling units related to the property that are income-restricted pursuant to Federal, State, or local affordable housing programs.

For the individual units field, this would encompass all types of dwellings, so if you had a 4br 2ba suburban home, you would enter '1'. If you have multiple properties and they are all 1-unit each, then you would add up all the 1-unit dwellings and report the combined number. If you have a 20-unit apartment building, then you would enter '20'. So, yes, this is not only applicable to manufactured homes or communities.

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#2161744 - 01/24/18 08:52 PM Re: Total Individual Units&Multifamily Affordable Uni TeamComply
RVFlyboy Offline
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There is no rhyme or reason to the way the CFPB ordered the fields.

The total number of units is for all collateral for the loan. The total number of multifamily affordable units is for all multifamily collateral for the loan.

Let's say you have 2 10-unit apartment buildings, each with 2 units that are affordable housing. You also have 3 single family manufactured homes. One of the 2 apartment buildings is the identified property on which you report address information. You would report total units as 23, and multifamily affordable units as 4.
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#2178603 - 05/17/18 08:22 PM Re: Total Individual Units&Multifamily Affordable Uni TeamComply
Norman Paperman Offline
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I'm going to jump in here since I've been looking this over. How, given the above, will regulators ever identify whether a property is 1-4 or multifamily, like they were able to back on the old LAR days? Or, do they even care anymore since we can separately identify affordable units?
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#2178640 - 05/18/18 11:44 AM Re: Total Individual Units&Multifamily Affordable Uni TeamComply
RVFlyboy Offline
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They can identify whether there is multifamily or not by whether you report a numeric value in the multifamily affordable units field. If you report NA in that field, there shouldn't be any multifamily collateral. If they do data integrity testing, they will probably look to the appraisal/valuation on the collateral to determine whether it was multifamily or not.
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#2178715 - 05/18/18 03:45 PM Re: Total Individual Units&Multifamily Affordable Uni TeamComply
Norman Paperman Offline
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Good point. I guess they only care whether the multifamily includes affordable (income-restricted) units. An apartment complex that didn't have income restricted units would still show N/A in that field, correct?
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#2178746 - 05/18/18 05:09 PM Re: Total Individual Units&Multifamily Affordable Uni TeamComply
Dan Persfull Offline
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An apartment complex that didn't have income restricted units would still show N/A in that field, correct?

You report 0.
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#2178766 - 05/18/18 05:42 PM Re: Total Individual Units&Multifamily Affordable Uni TeamComply
RVFlyboy Offline
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Dan is correct - for multifamily with no income restricted units you report 0. You only report NA if there is no multifamily securing the loan.
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#2178818 - 05/18/18 07:41 PM Re: Total Individual Units&Multifamily Affordable Uni TeamComply
Norman Paperman Offline
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Thank you gentlemen.
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Maybe you just wanna fly the plane yourself. Well good luck pressing take off, then auto pilot, then land.


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