We have a loan where the purpose is to purchase a SFR to convert to a social rehab center. However, the loan is being classified as unsecured, but we are taking different SFR as an abundance of caution.

My question is, since we are using the funds to purchase a different SFR than what is being taken as collateral, is it HMDA reportable? If so, what address do I use for the LAR and geocoding.

Thank you.

Official Interpretation
2(f) Dwelling
3. Exclusions. Recreational vehicles, including boats, campers, travel trailers, and park model recreational vehicles, are not considered dwellings for purposes of § 1003.2(f), regardless of whether they are used as residences. Houseboats, floating homes, and mobile homes constructed before June 15, 1976, are also excluded, regardless of whether they are used as residences. Also excluded are transitory residences such as hotels, hospitals, college dormitories, and recreational vehicle parks, and structures originally designed as dwellings but used exclusively for commercial purposes, such as homes converted to daycare facilities or professional offices.

That is what I thought. Thank you for the quick confirmation.

but we are taking different SFR as an abundance of caution.

Are you refinancing this or is it free and clear? Probably NOT refinancing, but that's what you need to look at in the scenario you described. If you paid off a loan secured by the true dwelling and the new loan [regardless of purpose of proceeds] is secured by that dwelling, it would be reportable.

I agree with Randy and Joker but just want to add: forget the "abundance of caution" thought. It doesn't matter for HMDA (or most all other regulatory requirements. If you have it, you have it.