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#2214688 - 05/31/19 03:14 PM 1-4 Family or Multi-Family
NJL Offline
New Poster
Joined: Jun 2013
Posts: 7
I have a commercial loan purchasing one parcel of land with two 3-unit buildings. For HMDA I would report this as a 6 unit. For CRA consideration; could this be considered a multi-family or no because it is two 1-4 family?

Thank you,

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#2214714 - 05/31/19 05:55 PM Re: 1-4 Family or Multi-Family NJL
WABComply Offline
100 Club
Joined: Jul 2017
Posts: 228
If you are reporting as a multifamily or now 6 unit on the HMDA LAR I would give it the same treatment for CRA purposes if the loan qualifies as a CDL. If it doesn't qualify it really doesn't matter.

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#2215810 - 06/14/19 08:40 PM Re: 1-4 Family or Multi-Family NJL
mrogersfib Offline
100 Club
Joined: Aug 2018
Posts: 116
Yes, under the new HMDA rules it would be coded as multi-family because it is a "community." So that would also make this eligible for CRA as well as long as the rent rates were to LMI or the sales price was below market median home prices.

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