We had a construction loan go to permanent financing. The permanent financing was to a Living Trust, signed by Trustees (it's their new house) but not as individuals. I'm struggling with HMDA codes. It went to Freddie Mac, so it was run as consumer purpose with all TRID disclosures, etc.

However, should we have collected demographic information since this was to a Trust and not individuals? Should I code as business purpose (and code all others accordingly (income NA, etc.) since it's to an entity?

Help please! I'm not terribly familiar with how trusts work so would love some guidance

I searched our training outline for "Trust" as I know there are different answers for this depending on what data you are reporting. Heres' various topics (more than you asked for) concerning reporting on trusts:

Demographic Info:
Report … the applicant’s or co-applicant’s ethnicity, race, and sex is not applicable when the applicant or co-applicant is not a natural person (for example, a corporation, partnership, or trust). [Appendix B to §1003 #7]

Do not report age …if the applicant or co-applicant is not a natural person (for example, a corporation, partnership, or trust). [Commentary to §1003.4(a)(10)(ii) #4]

Income:
Report …not applicable when the applicant or co-applicant is not a natural person (e.g., a corporation, partnership, or trust). [Commentary to §1003.4(a)(10)(iii) #7]

Business or Commercial Purpose:
HMDA refers to Reg Z. [§1003.4(a)(38)] so it's most likely a Code 2 "Not Primarily for a business or commercial purpose"