Would you include property that was taken as an abundance of Caution for Property Value and # of units when reporting HMDA data?

Yep. If you have an used the value. Units would count regardless.

What if they didn't use it's value in their CLTV?

If they don't use a value, you don't report the value. You only report what was considered in making the credit decision. However, that has no bearing on how many dwellings you have

Thanks RR Joker.

If a loan is secured by a non-dwelling as the primary collateral and a residential dwelling as an abundance of caution, is that HMDA reportable? If yes, does your answer change is the proceeds for the loan are not related to a consumer purpose?

Fair Warning: I am fairly new to banking and commercial/consumer lending, so I apologize in advance if my questions don't make complete sense. My background is with non-bank lenders that were 100% residential mortgage shops, so these commercial/consumer nuances are throwing me for a loop.

What is the purpose of the loan?

That is what I don't know how to answer. These loans are out of our SBA division and the funds are typically used to either consolidate existing debt, acquire commercial property, or purchase inventory.

SBA normally takes everything including the kitchen sink on their loans...which includes the borrower's/guarantor's principal residence. In my experience, they are collateral only and not for a purchase, refi or home improvement of that residence or any residence securing the SBA loan....so, not HMDA reportable, if that is the case.

I agree with crcmnot. There is no 'other' purpose for commercial/business loans.

Great, thank you, Skittles and crcmnot! Your responses have been very helpful!

Keep in mind that if you're paying off an existing dwelling-secured loan to the same borrower (such as a previous SBA loan), your new loan will be reportable.