When we have a commercial loan that is for the purchase/refinance of multiple properties and we take them all as collateral, what do we use to calculate the number of units and the property value fields?

I had been using the taking the total number of units from ALL of the collateral properties involved and totaling the appraisals for ALL of the properties for these fields but compliance has questioned us and feels that we should only be reporting the units and property value for the whatever would be considered the MAIN piece of collateral.

Which way would be correct?

And if we're to only use the information on the main piece of collateral how should we determine which piece that is if the lender says they took them all equally? Choose the one with the highest value?

Thanks!

Hi Whitney. follow this link to the guidance on reporting total units

https://www.consumerfinance.gov/policy-compliance/rulemaking/regulations/1003/4/#a-31

The number of units reported is the TOTAL number of units collateralizing the loans

The same goes for the value. It is the value of all the property collateralizing the loan, not just the value of the property address you choose to report.

Follow this link to what I use as my "bible" in completing HMDA. It contains what to enter into each reportable item, AND provides the regulatory reference for further explanation!

https://files.consumerfinance.gov/f...orting-overview-reference-chart-2019.pdf

Thanks so much Melissa! :-)

Question regarding multiple properties:
2 loans made at one time. First loan is c/o refi of primary residence for construction funds of an investment property. 2nd loan made is in the amount of $194500: $145,000 is for the purchase of land, which is securing the loan. In addition the loan will also be secured by a 2nd DOT on their PR, in the amount of $49,500.
Is the second loan HMDA reportable? If so, in what respect?
Thank you in advance

Please do not double post your questions.

Duplicate post