Our borrowers are getting a construction-to-perm loan for $250,000. They'll use $150,000 to purchase a motel and $100,000 to convert the motel to multi-family rental housing. Is this transaction HMDA reportable? If so, I'm assuming we'd report it as a purchase and state that the number of units would be the number of apartments once the conversion has been completed. Am I correct? Thank you!

you are correct. You report the borrower's intended use of the building. Your loan will be creating a multi-family dwelling so it would be a purchase and report the number of units the building will contain.

Thank you!