Hi,
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,

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.

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.