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#2195045 - 10/09/18 08:49 PM Purchase property not used as collateral
KelliD Offline
Member
Joined: Jun 2015
Posts: 62
I have a property being purchased but it is not the collateral. There are other properties securing the loan. So, do I report the property location as the one being purchased? It's not securing the loan which is causing the confusion.

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#2195050 - 10/09/18 09:24 PM Re: Purchase property not used as collateral KelliD
raitchjay Offline
Power Poster
Joined: Oct 2009
Posts: 8,840
OK
You report the collateral property. If multiple 1-4 properties secure the loan, pick one of them.
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#2195071 - 10/10/18 12:56 PM Re: Purchase property not used as collateral KelliD
Adam Witmer Offline
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Joined: Sep 2010
Posts: 2,643
raitchjay is correct.

In case you were wanting the citation (and further explanation) on this, we turn to comment 4(a)(9)-2:
"2. Multiple properties with more than one property taken as security. If more than one property is taken or, in the case of an application, proposed to be taken as security for a single covered loan, a financial institution reports the covered loan or application in a single entry on its loan/application register and provides the information required by § 1003.4(a)(9) for one of the properties taken as security that contains a dwelling. A financial institution does not report information about the other properties taken as security. If an institution is required to report specific information about the property identified in § 1003.4(a)(9), the institution reports the information that relates to the property identified in § 1003.4(a)(9). For example, Financial Institution A originated a covered loan that is secured by both property A and property B, each of which contains a dwelling. Financial Institution A reports the loan as one entry on its loan/application register, reporting the information required by § 1003.4(a)(9) for either property A or property B. If Financial Institution A elects to report the information required by § 1003.4(a)(9) about property A, Financial Institution A also reports the information required by § 1003.4(a)(5), (6), (14), (29), and (30) related to property A. For aspects of the entries that do not refer to the property identified in § 1003.4(a)(9) (i.e., § 1003.4(a)(1) through (4), (7), (8), (10) through (13), (15) through (28), (31) through (38)), Financial Institution A reports the information applicable to the covered loan or application and not information that relates only to the property identified in § 1003.4(a)(9)."
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Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

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#2195072 - 10/10/18 12:57 PM Re: Purchase property not used as collateral KelliD
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,967
Bloomington, IN
The regulation is pretty clear on which property to report.

1003.4(a)(9) The following information about the location of the property securing the covered loan or, in the case of an application, proposed to secure the covered loan:


2. Multiple properties with more than one property taken as security. If more than one property is taken or, in the case of an application, proposed to be taken as security for a single covered loan, a financial institution reports the covered loan or application in a single entry on its loan/application register and provides the information required by § 1003.4(a)(9) for one of the properties taken as security that contains a dwelling
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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